Moss American, Inc. v. Commissioner
United States Tax Court
Petitioner's predecessor purchased all the outstanding stock of another corporation for an adjusted cost of $8,767,184.17 and immediately liquidated it under sec. 332, I.R.C. 1954. It allocated its adjusted cost of the stock to the net assets received under the provisions of sec. 334(b) (2), I.R.C. 1954, based on a total fair market value of assets equal to its cost of the stock.
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Petitioner's predecessor purchased all the outstanding stock of another corporation for an adjusted cost of $8,767,184.17 and immediately liquidated it under sec. 332, I.R.C. 1954. It allocated its adjusted cost of the stock to the net assets received under the provisions of sec. 334(b) (2), I.R.C. 1954, based on a total fair market value of assets equal to its cost of the stock. The Commissioner reallocated the adjusted cost on the basis of fair market value aggregating $21,270,208.72. Held, the aggregate fair market value of the assets received in liquidation for purposes of applying sec.…
1Opinion of the Court
MOSS AMERICAN, INC., Successor By Merger to T.J. Moss Tie Company (Delaware), Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Moss American, Inc. v. Commissioner
Docket No. 6065-71.
United States Tax Court
T.C. Memo 1974-252; 1974 Tax Ct. Memo LEXIS 68; 33 T.C.M. (CCH) 1121; T.C.M. (RIA) 74252;
September 23, 1974, Filed.
Petitioner's predecessor purchased all the outstanding stock of another corporation for an adjusted cost of $8,767,184.17 and immediately liquidated it under sec. 332, I.R.C. 1954. It allocated its adjusted cost of the stock to the net assets received under the…
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