Legal Opinion

Grubbs v. Commissioner

United States Tax Court

Decided October 8, 1962No. Docket No. 89633Published

Petitioner held stock in a California corporation operating a Ford dealership which had accumulated earnings but had never declared a dividend. Another stockholder, who had operated, as sole proprietor, a supervisory service for dealers, transferred this business to a new corporation, organized in Tennessee, for class A stock.

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Petitioner held stock in a California corporation operating a Ford dealership which had accumulated earnings but had never declared a dividend. Another stockholder, who had operated, as sole proprietor, a supervisory service for dealers, transferred this business to a new corporation, organized in Tennessee, for class A stock. The assets and franchise of the dealership were transferred to the new corporation for cash, which was distributed by the old corporation to all its stockholders (except one) for their stock and all the stockholders acquired class B stock in the new corporation. After…

1Opinion of the Court

David T. Grubbs and Margaret S. Grubbs, Petitioners, v. Commissioner of Internal Revenue, Respondent

Grubbs v. Commissioner

Docket No. 89633

United States Tax Court

39 T.C. 42; 1962 U.S. Tax Ct. LEXIS 58;

October 8, 1962, Filed

Decision will be entered under Rule 50.

Petitioner held stock in a California corporation operating a Ford dealership which had accumulated earnings but had never declared a dividend. Another stockholder, who had operated, as sole proprietor, a supervisory service for dealers, transferred this business to a new corporation, organized in Tennessee, for class A stock. The…

2Cases cited14 opinions

  1. Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
  2. Hellmich v. HellmanSupreme Court of the United States · 1928
  3. United States v. John H. FewellCourt of Appeals for the Fifth Circuit · 1958
  4. Survaunt v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1947
  5. William Liddon v. Commissioner of Internal Revenue, Maria Prothro Liddon v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956

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