Legal Opinion

T. v. D. Co. v. Commissioner

United States Tax Court

Decided February 28, 1957No. Docket No. 58804PublishedCited by 29 opinions

In 1951 the Bank of America acquired all the stock of Enterprise Productions, Inc., an unsuccessful motion picture corporation, in foreclosing defaulted loans. On April 30, 1952, Enterprise, aided by a loan from the bank, purchased all the stock of petitioner, a successful soap manufacturer.

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In 1951 the Bank of America acquired all the stock of Enterprise Productions, Inc., an unsuccessful motion picture corporation, in foreclosing defaulted loans. On April 30, 1952, Enterprise, aided by a loan from the bank, purchased all the stock of petitioner, a successful soap manufacturer. The loan agreement provided that all operating assets of petitioner would be taken over by Enterprise and that after April 30, 1952, petitioner would do nothing more than liquidate certain assets and pay certain liabilities. This was done. After that date Enterprise carried on the soap business and from…

1Opinion of the Court

OPINION.

Tietjens, Judge:

The facts as recited by counsel for the petitioner in his opening statement to the Court have been stipulated to be the facts. They are so found and are incorporated herein by this reference.

The petitioner, the T. V. D. Co., is an Ohio corporation having its principal office in Cincinnati, Ohio. It was originally known as the DuBois Co. The petitioner had, for a number of years prior to April 30, 1952, been engaged in the manufacture and sale of soap and other cleaning materials. At that time about 90 per cent of its stock was owned by members of the DuBois family.

Enter…

2Cases cited6 opinions

  1. Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
  2. Commodores Point Terminal Corp. v. CommissionerUnited States Tax Court · 1948
  3. Polak's Frutal Works, Inc. v. CommissionerUnited States Tax Court · 1954
  4. Estate of Byrne v. CommissionerUnited States Tax Court · 1951
  5. Twin Oaks Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950

1 more not listed; retrieve them via the Exa API.

3Cited by29 opinions

  1. Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
  2. Ballentine Motor Co. v. CommissionerUnited States Tax Court · 1962
  3. Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969
  4. James Realty Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
  5. Brittingham v. CommissionerUnited States Tax Court · 1976

24 more not listed; retrieve them via the Exa API.

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