Legal Opinion
Estate of Lockwood v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided September 17, 1965No. 17908PublishedCited by 5 opinions
1Opinion of the Court
VOGEL, Circuit Judge.
The single question involved in this review of an unreported decision of the Tax Court of the United States, entered August 26, 1964, is whether the “spinoff” of part of the business conducted by the Lockwood Grader Corporation of Ger-ing, Nebraska, (hereinafter Lockwood) through the organization of a new corporation, Lockwood Graders of Maine, Inc. (hereinafter Maine, Inc.) was tax-free to petitioners, recipients of the stock of Maine, Inc., under 26 U.S.C.A. § 355 (Int. Rev.Code).1 The government contended that the spin-off was not tax-free since the requirements of §…
2Cases cited9 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Coady v. CommissionerUnited States Tax Court · 1960
- United States v. W. W. Marett and Ruth MarettCourt of Appeals for the Fifth Circuit · 1963
- Elliott v. CommissionerUnited States Tax Court · 1959
- Henry H. Bonsall, Jr., and Martha G. Bonsall, C. Jordan Vail and Nancy B. Vail v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
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3Cited by5 opinions
- Atlee v. CommissionerUnited States Tax Court · 1976
- Atlee v. CommissionerUnited States Tax Court · 1976
- Boettger v. CommissionerUnited States Tax Court · 1968
- Estate Of Thorval J. Lockwood, DeceasedCourt of Appeals for the First Circuit · 1965
- Nielsen v. CommissionerUnited States Tax Court · 1973