Chilhowee Mills, Inc. v. Commissioner
United States Tax Court
In 1937 Chilhowee Mills, Inc., granted an option to purchase covering all its property. Later in that year the corporation dissolved and the stockholders formed a partnership to carry on the corporate business. Partnership books were opened in which each partner's interest was shown to be his proportionate interest as a stockholder in the capital surplus and undivided profits of the corporation.
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In 1937 Chilhowee Mills, Inc., granted an option to purchase covering all its property. Later in that year the corporation dissolved and the stockholders formed a partnership to carry on the corporate business. Partnership books were opened in which each partner's interest was shown to be his proportionate interest as a stockholder in the capital surplus and undivided profits of the corporation. The title to the corporate property remained in the corporation, but the property was used by the partnership. In March 1938 the option was extended by a contract executed by the corporation as a…
1Opinion of the Court
OPINION.
Keen, Judge'.
This case comes up on respondent’s determination of a deficiency in the income tax of petitioner corporation for the fiscal year 1939 in the sum of $11,265.87, and of transferee liability against the other petitioners. Petitioner corporation filed no income tax return for the taxable year. The notice of deficiency was mailed to petitioner corporation on July 17, 1943. These cases are related to the case bearing Docket No. 108922, in which our decision was promulgated on September 16,1942, and reported at 47 B. T. A. 682. In the decided case the deficiency was determined…
2Cases cited2 opinions
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Hilpert v. CommissionerUnited States Tax Court · 1944
3Cited by20 opinions
- Boulez v. CommissionerUnited States Tax Court · 1981
- Malinowski v. CommissionerUnited States Tax Court · 1979
- Vestal v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1945
- Fairmont Aluminum Co. v. CommissionerUnited States Tax Court · 1954
- Howell Turpentine Co. v. CommissionerUnited States Tax Court · 1946
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