Legal Opinion
Hanson v. United States
District Court, D. Montana
Decided December 29, 1971No. Civ. 637-638PublishedCited by 3 opinions
1Opinion of the Court
ORDER AND MEMORANDUM OPINION
JAMESON, District Judge.
These actions were brought pursuant to 28 U.S.C. § 1346(a) (1), to recover income taxes paid by the plaintiffs for the year 1955. 1 At issue in each case is whether a distribution of stock of Hanson-Mersen Motors, Inc. to the shareholders of H-M Corporation qualified for tax free status as a “spin-off” under Section 355 of the Internal Revenue Code of 1954, 26 U.S.C. § 355, or was taxable to the plaintiffs as an ordinary dividend under Section 301(c) (1).
The parties express no disagreement as to the underlying facts and most have been…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. GordonSupreme Court of the United States · 1968
- American Sav. Bank v. CommissionerUnited States Tax Court · 1971
- Henry H. Bonsall, Jr., and Martha G. Bonsall, C. Jordan Vail and Nancy B. Vail v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Commissioner of Internal Revenue v. Marne S. Wilson, Marjorie M. Wilson, Lyle C. Wilson and Peggy WilsonCourt of Appeals for the Ninth Circuit · 1965
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3Cited by3 opinions
- Gada v. United StatesDistrict Court, D. Connecticut · 1978
- Omaha Aircraft Leasing Co. v. CommissionerUnited States Tax Court · 1980
- Omaha Aircraft Leasing Co. v. CommissionerUnited States Tax Court · 1980