Dudley v. Commissioner
United States Tax Court
1. Held, that the formation of National Tanker Corporation by stockholders of American Overseas Tanker Corporation (AOTC), the transfer to National of AOTC's right to purchase certain tankers, and the ultimate sale of National stock to United Tanker Corporation were merely steps in a transaction designed as a sale of the tankers by AOTC to United at a profit to AOTC of $ 450,000; hence, the distribution of that amount to National stockholders, petitioners herein, was in…
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1. Held, that the formation of National Tanker Corporation by stockholders of American Overseas Tanker Corporation (AOTC), the transfer to National of AOTC's right to purchase certain tankers, and the ultimate sale of National stock to United Tanker Corporation were merely steps in a transaction designed as a sale of the tankers by AOTC to United at a profit to AOTC of $ 450,000; hence, the distribution of that amount to National stockholders, petitioners herein, was in effect a dividend to them from AOTC. 2. Held, further, that United's promissory note was intended merely as evidence of its…
1Opinion of the Court
Virginia W. Stettinius Dudley, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Dudley v. Commissioner
Docket Nos. 62570, 62571, 63143-63148, 63529-63537, 63713, 63714, 63715, 63915, 63916
United States Tax Court
32 T.C. 564; 1959 U.S. Tax Ct. LEXIS 164;
May 29, 1959, Filed
Decisions will be entered under Rule 50.
1. Held, that the formation of National Tanker Corporation by stockholders of American Overseas Tanker Corporation (AOTC), the transfer to National of AOTC's right to purchase certain tankers, and the ultimate sale of National stock to United Tanker Corporation were…
2Cases cited22 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
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