Pittman v. Commissioner
United States Tax Court
The petitioner is transferee of a corporation dissolved in 1945. In 1947, based on a stipulation of the parties, this Court entered its decision that the dissolved corporation owed an additional tax on its 1945 income and that the petitioner, as transferee, was liable therefor. In 1947 the petitioner paid this additional tax.
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The petitioner is transferee of a corporation dissolved in 1945. In 1947, based on a stipulation of the parties, this Court entered its decision that the dissolved corporation owed an additional tax on its 1945 income and that the petitioner, as transferee, was liable therefor. In 1947 the petitioner paid this additional tax. On May 17, 1946, petitioner filed her income tax return for 1945, reporting a gain on the liquidation of the corporation of $ 19,686.91. The respondent determined that this gain should have been $ 21,669.61. In so doing, the respondent refused to allow petitioner to…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The sole issue is whether or not the petitioner, as transferee of the dissolved corporation, is entitled to deduct the Federal income tax on the corporation paid by her in 1947 from the gain realized in 1945 on the liquidation of such corporation.
The petitioner contends that she should be allowed to decrease the value of the assets which she received upon dissolution of the corporation by the amount of taxes which, as transferee, she paid in a later year. Thus, as the petitioner sees the issue, it involves the adjustment or redetermination of the amount of the…
2Cases cited5 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Mills v. CommissionerUnited States Tax Court · 1945
- Switlik v. CommissionerUnited States Tax Court · 1949
3Cited by23 opinions
- Vaira v. CommissionerUnited States Tax Court · 1969
- Stein v. CommissionerUnited States Tax Court · 1956
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- Schneider v. CommissionerUnited States Tax Court · 1975
- Archbishop Samuel Trust v. CommissionerUnited States Tax Court · 1961
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