Field v. Commissioner
United States Tax Court
A Michigan corporation was dissolved on April 27, 1951. Under Michigan law its corporate existence continued for 3 years, or longer, for the purpose of settling its affairs and concluding a proceeding commenced by it prior to dissolution or within the 3-year winding-up period. Immediately after dissolution, all of the corporation's assets were distributed to its stockholders.
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A Michigan corporation was dissolved on April 27, 1951. Under Michigan law its corporate existence continued for 3 years, or longer, for the purpose of settling its affairs and concluding a proceeding commenced by it prior to dissolution or within the 3-year winding-up period. Immediately after dissolution, all of the corporation's assets were distributed to its stockholders. At the time of dissolution, the corporation's liability for Federal taxes was in dispute and unsettled. The corporation, through its officers and liquidating directors, respectively, executed successive waivers in…
1Opinion of the Court
OPINION.
HaRRON, Judge:
The issue to be decided is whether the statutory notices of transferee liability for tax deficiencies of Adwood Corporation were timely so that assessments of transferee liability are not barred by the statute of limitations. Petitioners concede that they are the transferees of the corporation and that they would be liable for the assessments if they are not barred by the statute of limitations. The Value of the property of Adwood received by each petitioner and the amount of each transferee’s liability has been stipulated.
Section 311 (b) of the 1939 Code4 provides that…
2Cases cited29 opinions
- Chicago Title & Trust Co. v. Forty-One Thirty-Six Wilcox Bldg. Corp.Supreme Court of the United States · 1937
- Oklahoma Natural Gas Co. v. OklahomaSupreme Court of the United States · 1927
- Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
- Stott v. Stott Realty Co.Michigan Supreme Court · 1939
- Benoit v. CommissionerUnited States Tax Court · 1955
24 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- Looper v. CommissionerUnited States Tax Court · 1980
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
- Badger Materials, Inc. v. CommissionerUnited States Tax Court · 1963
- Bos Lines, Inc. v. CommissionerUnited States Tax Court · 1965
14 more not listed; retrieve them via the Exa API.