George L. Riggs, Inc. v. Commissioner
United States Tax Court
Held: Sec. 332, I.R.C. 1954, applicable to avoid recognition of gain on liquidation of subsidiary. Taxpayer owned 80 percent of the stock of the subsidiary on the date of the adoption of the plan of liquidation within the meaning of sec. 332(b).
1Opinion of the Court
Drennen, Judge:
Respondent determined a deficiency in petitioner’s income tax for the taxable year ended March 31, 1969, in the amount of $589,882.28.
The sole issue for determination is whether the plan of liquidation of Riggs-Young Corp., a subsidiary of the petitioner, was adopted subsequent to the time when petitioner owned at least 80 percent of the outstanding stock of Riggs-Young, thereby rendering section 332,1.R.C. 1954, applicable to the liquidation so that the gain to petitioner thereon is not to be recognized.
FINDINGS OF FACT
Some of the facts have been stipulated and are found…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Sandor v. CommissionerUnited States Tax Court · 1974
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Palmer v. CommissionerUnited States Tax Court · 1974
- J. C. Penney Co. v. CommissionerUnited States Tax Court · 1962
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3Cited by3 opinions
- Associated Wholesale Grocers, Inc., and Its Subsidiary, Super Market Developers, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1991
- Barkley Co. of Arizona v. CommissionerUnited States Tax Court · 1988
- George L. Riggs, Inc. v. CommissionerUnited States Tax Court · 1975