Nielsen v. Commissioner
United States Tax Court
For more than 5 years preceding Mar. 31, 1964, Oak Park operated a hospital in Stockton, Calif. On Aug. 14, 1961, Oak Park purchased a hospital in Los Angeles, Calif. Although the two hospitals shared some management and professional services, each hospital had a separate medical staff, served patients living primarily within its own geographical area, and functioned independently of the other hospital.
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For more than 5 years preceding Mar. 31, 1964, Oak Park operated a hospital in Stockton, Calif. On Aug. 14, 1961, Oak Park purchased a hospital in Los Angeles, Calif. Although the two hospitals shared some management and professional services, each hospital had a separate medical staff, served patients living primarily within its own geographical area, and functioned independently of the other hospital. After a dispute arose among the shareholders of Oak Park, an agreement was reached to split up Oak Park into two corporations. On Mar. 31, 1964, Oak Park distributed to a group of its…
1Opinion of the Court
OPINION
Irwin, Judge:
Respondent determined the following deficiencies and overpayments in the income taxes of petitioners:
Docket No. Year Deficiency Overassessmont
2893-70 (19641 119651 $8,413.99 $62
2894-70 (19641 11965/ 6,786.61 128
In docket No. 2893-70 petitioner offered no evidence or argument with respect to a casualty loss issue, and we deem that issue to have been conceded by petitioner. Accordingly, the only issue for determination is whether petitioners may treat distributions of stock received by them in 1964 in a corporate splitup as nontaxable under section 355 (a).1
All of the facts…
2Cases cited6 opinions
- 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
- Badanes v. CommissionerUnited States Tax Court · 1962
- Burke v. CommissionerUnited States Tax Court · 1964
1 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Atlee v. CommissionerUnited States Tax Court · 1976
- Scheidt v. CommissionerUnited States Tax Court · 1992
- Atlee v. CommissionerUnited States Tax Court · 1976
- Fuentes v. Comm'rUnited States Tax Court · 2009
- Gist v. Comm'rUnited States Tax Court · 2009
4 more not listed; retrieve them via the Exa API.