Colt's Mfg. Co. v. Commissioner
United States Tax Court
1. Held, when viewed in the light of all the facts and circumstances, the 120,000 shares of its own stock, which petitioner had acquired in May 1950, pursuant to a resolution adopted by its stockholders authorizing the directors "to purchase or otherwise acquire outstanding shares of the capital stock of the company and to hold, sell, exchange, transfer or retire said shares from time to time, to such an extent, in such manner and upon such terms as the directors may deem…
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1. Held, when viewed in the light of all the facts and circumstances, the 120,000 shares of its own stock, which petitioner had acquired in May 1950, pursuant to a resolution adopted by its stockholders authorizing the directors "to purchase or otherwise acquire outstanding shares of the capital stock of the company and to hold, sell, exchange, transfer or retire said shares from time to time, to such an extent, in such manner and upon such terms as the directors may deem advisable," and which shares were thereafter held in the treasury until canceled and retired on December 18, 1952, are…
1Opinion of the Court
Colt's Manufacturing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Colt's Mfg. Co. v. Commissioner
Docket No. 59184
United States Tax Court
35 T.C. 78; 1960 U.S. Tax Ct. LEXIS 46;
October 21, 1960, Filed
Decision will be entered under Rule 50.
1. Held, when viewed in the light of all the facts and circumstances, the 120,000 shares of its own stock, which petitioner had acquired in May 1950, pursuant to a resolution adopted by its stockholders authorizing the directors "to purchase or otherwise acquire outstanding shares of the capital stock of the company and to hold, sell,…
Also in this document: Dissent · Murdock; Dissent · Drennen.
2Cases cited5 opinions
- Chesbro v. CommissionerUnited States Tax Court · 1953
- Helvering v. Edison Bros. Stores, Inc.Court of Appeals for the Eighth Circuit · 1943
- United States v. Anderson, Clayton & Co.Supreme Court of the United States · 1955
- Colt's Mfg. Co. v. CommissionerUnited States Tax Court · 1960
- Sandoval Zinc Co. v. CommissionerUnited States Tax Court · 1958