Legal Opinion
Commissioner of Internal Revenue v. Kay Mfg. Corp.
Court of Appeals for the Second Circuit
Decided August 5, 1941No. 366PublishedCited by 3 opinions
1Opinion of the Court
SWAN, Circuit Judge.
There is no dispute as to the facts, all of which were stipulated. The taxpayer, Kay Manufacturing Corporation, is a Massachusetts corporation whose capital stock was owned by a New York corporation of the same name. During the taxable year in suit the taxpayer distributed all. its assets in complete liquidation, and was thereafter dissolved. Such distribution was a transaction upon which no gain or loss to the parent corporation is recognized under the provisions of section 112(b) (6) of the Revenue Act of 1936, 26 U.S.C.A. Int. Rev.Acts, page 856. At the date of…
2Cases cited5 opinions
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Credit Alliance Corp. v. CommissionerUnited States Board of Tax Appeals · 1940
- Helvering v. Credit Alliance Corp.Court of Appeals for the Fourth Circuit · 1941
- Centennial Oil Co. v. ThomasCourt of Appeals for the Fifth Circuit · 1940
- Wild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
3Cited by3 opinions
- Helvering v. Credit Alliance Corp.Supreme Court of the United States · 1942
- Fowler Bros. & Cox, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Great Lakes Coco-Cola Bottling Co. v. CommissionerCourt of Appeals for the Seventh Circuit · 1943