Pitcher v. Commissioner
United States Tax Court
Petitioners unsuccessfully sought a favorable ruling under sec. 367, I.R.C. 1954, regarding an exchange of all the outstanding shares of YPI, a domestic corporation, for a majority interest in YPL, a Canadian corporation holding the YPI shares as its only asset, followed by a public offering by YPL of its shares on a Canadian stock exchange.
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Petitioners unsuccessfully sought a favorable ruling under sec. 367, I.R.C. 1954, regarding an exchange of all the outstanding shares of YPI, a domestic corporation, for a majority interest in YPL, a Canadian corporation holding the YPI shares as its only asset, followed by a public offering by YPL of its shares on a Canadian stock exchange. Held, in light of all the facts and circumstances, respondent's ruling that petitioners' transfer had as one of its principal purposes the avoidance of Federal income taxes was unreasonable.
1Opinion of the Court
Robert G. Pitcher, Millard G. Trask, Mary Jane Westermark, M. K. Jones, Petitioners v. Commissioner of Internal Revenue, Respondent
Pitcher v. Commissioner
Docket No. 21823-82T
United States Tax Court
84 T.C. 85; 1985 U.S. Tax Ct. LEXIS 132; 84 T.C. No. 6;
January 23, 1985. January 23, 1985, Filed
Petitioners unsuccessfully sought a favorable ruling under sec. 367, I.R.C. 1954, regarding an exchange of all the outstanding shares of YPI, a domestic corporation, for a majority interest in YPL, a Canadian corporation holding the YPI shares as its only asset, followed by a public offering by YPL of its…
2Cases cited8 opinions
- United States v. PyneSupreme Court of the United States · 1941
- Powell v. RothensiesCourt of Appeals for the Third Circuit · 1950
- Dittler Bros., Inc. v. CommissionerUnited States Tax Court · 1979
- Hershey Foods Corp. v. CommissionerUnited States Tax Court · 1981
- Gerli & Co. v. CommissionerUnited States Tax Court · 1980
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