Legal Opinion

Estate of McWhorter v. Commissioner

United States Tax Court

Decided February 2, 1978No. Docket Nos. 6653-74, 6654-74, 6655-74Published

On Aug. 28, 1970, Ozark declared dividends to shareholders of record on Sept. 30, 1970, payable Oct. 1, 1970. On Oct. 1, 1970, promissory notes with a face value equal to the declared dividends were issued to the shareholders. On Apr. 12, 1971, Ozark acquired 100 percent ownership in a previously unrelated corporation, Benton. On Apr. 30, 1971, Benton was merged into Ozark.

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On Aug. 28, 1970, Ozark declared dividends to shareholders of record on Sept. 30, 1970, payable Oct. 1, 1970. On Oct. 1, 1970, promissory notes with a face value equal to the declared dividends were issued to the shareholders. On Apr. 12, 1971, Ozark acquired 100 percent ownership in a previously unrelated corporation, Benton. On Apr. 30, 1971, Benton was merged into Ozark. Held, the property distributions occurred on Oct. 1, 1970; there were no earlier constructive distributions. Held, further: The purchase and liquidation of Benton did not qualify as one of the transactions described in…

1Opinion of the Court

Estate of Ward T. McWhorter, Deceased, Lynn Mabry and Clayton W. McWhorter, Co-Executors, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of McWhorter v. Commissioner

Docket Nos. 6653-74, 6654-74, 6655-74

United States Tax Court

69 T.C. 650; 1978 U.S. Tax Ct. LEXIS 185;

February 2, 1978, Filed

Decisions will be entered for the respondent.

On Aug. 28, 1970, Ozark declared dividends to shareholders of record on Sept. 30, 1970, payable Oct. 1, 1970. On Oct. 1, 1970, promissory notes with a face value equal to the declared dividends were issued to the shareholders. On Apr.…

2Cases cited23 opinions

  1. Anderson v. HelveringSupreme Court of the United States · 1940
  2. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
  3. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  4. United States v. KaiserSupreme Court of the United States · 1960
  5. J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966

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