Trianon Hotel Co. v. Commissioner
United States Tax Court
Trianon Hotel Company acquired all of the outstanding stock of the Allis Hotel Corporation and liquidated the latter corporation about a year later, thereby acquiring the liquidated corporation's assets. Trianon distributed $ 2,342,925 in cash and notes to the shareholders of Allis Corporation in acquiring their stock.
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Trianon Hotel Company acquired all of the outstanding stock of the Allis Hotel Corporation and liquidated the latter corporation about a year later, thereby acquiring the liquidated corporation's assets. Trianon distributed $ 2,342,925 in cash and notes to the shareholders of Allis Corporation in acquiring their stock. Allis, Shanberg, and Woolf, on the date of the transfer of their Allis Corporation stock to Trianon, together owned approximately 82.57 per cent of the outstanding stock of Allis Corporation, and approximately 79.11 per cent of the outstanding stock of Trianon. Amounts…
1Opinion of the Court
In Docket No. 60338, Trianon Hotel Company, the Commissioner determined for the taxable year 1952, deficiencies in income tax and excess profits tax in the total amount of $210,602.94. The Commissioner has made claim under section 272 (e), 1939 Code, for increase in the deficiency, the amount to be computed under Kule 50.
The chief issue in Docket No. 60338 is the basis to Trianon Hotel Company, for purposes of depreciation, amortization, and sale or other disposition, of the assets it acquired through the liquidation of the Allis Hotel Corporation whose stock was acquired by Trianon Hotel…
2Cases cited13 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. Ashland Oil & Refining Co.Court of Appeals for the Sixth Circuit · 1938
- Kanawha Gas & Utilities Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
- Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
8 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Richard R. Riss, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Ward v. CommissionerUnited States Tax Court · 1986
- Commissioner of Internal Revenue v. Walter L. And Helen MorganCourt of Appeals for the Third Circuit · 1961
- Gallagher v. CommissionerUnited States Tax Court · 1962
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