Legal Opinion

Schmidt v. Commissioner

United States Tax Court

Decided November 24, 1970No. Docket No. 5824-67Published

Petitioner owned 812 of 1,353 shares of Highland Co., a road construction corporation, having a total basis of $ 62,440. In 1965, pursuant to a plan of complete liquidation, the corporation sold its tangible assets and distributed $ 44,000, pro rata, to its stockholders.

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Petitioner owned 812 of 1,353 shares of Highland Co., a road construction corporation, having a total basis of $ 62,440. In 1965, pursuant to a plan of complete liquidation, the corporation sold its tangible assets and distributed $ 44,000, pro rata, to its stockholders. Its remaining assets, consisting of cash, "street warrants" and accounts receivable had an aggregate face value of $ 47,149.85. Its net worth, per books, was $ 42,644.71. Petitioner received $ 26,406.51 of the liquidating dividend, leaving $ 36,033.49 of her basis unrecovered as of the end of 1965. Her equitable interest in…

1Opinion of the Court

Ethel M. Schmidt, Petitioner v. Commissioner of Internal Revenue, Respondent

Schmidt v. Commissioner

Docket No. 5824-67

United States Tax Court

55 T.C. 335; 1970 U.S. Tax Ct. LEXIS 28;

November 24, 1970, Filed

Decision will be entered for the respondent.

Petitioner owned 812 of 1,353 shares of Highland Co., a road construction corporation, having a total basis of $ 62,440. In 1965, pursuant to a plan of complete liquidation, the corporation sold its tangible assets and distributed $ 44,000, pro rata, to its stockholders. Its remaining assets, consisting of cash, "street warrants" and accounts…

2Cases cited16 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Weiss v. WeinerSupreme Court of the United States · 1929
  3. Dresser v. United StatesUnited States Court of Claims · 1932
  4. Gowen v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1933
  5. Hyman v. HelveringCourt of Appeals for the D.C. Circuit · 1934

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