Andrews v. Commissioner
United States Tax Court
On July 29, 1966, petitioner received a 30 percent interest in Holiday Realty, Inc., in Exchange for his 30 percent interest in Holiday Harbor, Inc. In 1969, Holiday Realty, Inc., was liquidated. Petitioner's basis in his 30 percent interest in the liquidated corporation was the fair market value of such stock on the date it was received. Held, the fair market value of such 30 percent interest in Holiday Realty, Inc., was $ 1,157.50 on July 29, 1966.
1Opinion of the Court
WALTER G. ANDREWS and LOUISE S. ANDREWS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Andrews v. Commissioner
Docket No. 2482-73.
United States Tax Court
T.C. Memo 1976-106; 1976 Tax Ct. Memo LEXIS 298; 35 T.C.M. (CCH) 459; T.C.M. (RIA) 760106;
April 5, 1976, Filed
On July 29, 1966, petitioner received a 30 percent interest in Holiday Realty, Inc., in Exchange for his 30 percent interest in Holiday Harbor, Inc. In 1969, Holiday Realty, Inc., was liquidated. Petitioner's basis in his 30 percent interest in the liquidated corporation was the fair market value of such stock on the date…
2Cases cited8 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
- Estate of Heckscher v. CommissionerUnited States Tax Court · 1975
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3Cited by1 opinion
- Irene Eisenberg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998