Troy State University v. Commissioner
United States Tax Court
Two individuals transferred to petitioner, an educational institution managed and controlled by a State board of education, all the issued and outstanding stock of T, a corporation which held and rented hospital facilities.
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Two individuals transferred to petitioner, an educational institution managed and controlled by a State board of education, all the issued and outstanding stock of T, a corporation which held and rented hospital facilities. Immediately after the transfer, petitioner caused T to be liquidated and to distribute to petitioner all of its assets, including certain property described in sec. 1245(a)(3), I.R.C. 1954. Held, neither sec. 115(a)(1), I.R.C. 1954, nor constitutional limitations on Federal taxing power exempt from tax the amount treated as gain by sec. 1245, I.R.C. 1954.
1Opinion of the Court
Troy State University, Petitioner v. Commissioner of Internal Revenue, Respondent
Troy State University v. Commissioner
Docket No. 7516-72
United States Tax Court
62 T.C. 493; 1974 U.S. Tax Ct. LEXIS 77; 62 T.C. No. 54;
July 9, 1974, Filed
Decision will be entered under Rule 155.
Two individuals transferred to petitioner, an educational institution managed and controlled by a State board of education, all the issued and outstanding stock of T, a corporation which held and rented hospital facilities. Immediately after the transfer, petitioner caused T to be liquidated and to distribute to petitioner…
2Cases cited31 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Commissioner v. SternSupreme Court of the United States · 1958
- South Carolina v. United StatesSupreme Court of the United States · 1905
- Collector v. DaySupreme Court of the United States · 1871
- Helvering v. GerhardtSupreme Court of the United States · 1938
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