Arlington Metal Industries, Inc. v. Commissioner
United States Tax Court
Petitioner is the successor corporation to ATI, Inc. In 1965, the majority stockholder of ATI caused investigations to be made of two of the corporation's managing officers and directors, B and W, for alleged mismanagement and possible theft of scrap metal.
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Petitioner is the successor corporation to ATI, Inc. In 1965, the majority stockholder of ATI caused investigations to be made of two of the corporation's managing officers and directors, B and W, for alleged mismanagement and possible theft of scrap metal. ATI and B and W executed a mutual release wherein the two stockholders agreed to surrender their stock (1,368 shares) to the corporation and to forgive the corporation's liability ($ 17,556.06) to them in consideration of any claims the corporation might have against them. ATI was not insolvent when the mutual release was executed. Held,…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Taxable year ended Amount
Mar. 31,1966_$1, 693. 64
Mar. 31,1967_ 10,225.44
As contained in the stipulation of facts, various adjustments made in respondent’s notice of deficiency have been resolved by agreement of the parties and can be given effect in the Rule 50 computation. Two issues remain for our decision: (1) Did petitioner realize taxable income of $33,420.24 in its taxable year ended March 31, 1966, when it received 1,368 shares of its stock? (2) Did petitioner correctly include in…
2Cases cited17 opinions
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
- H. Liebes & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1937
12 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
- Arlington Metal Industries, Inc. v. CommissionerUnited States Tax Court · 1971
- Esmark, Inc. v. CommissionerUnited States Tax Court · 1988