De Groff v. Commissioner
United States Tax Court
Petitioners (T and his wife) were the sole and equal stockholders in three corporations, M, P, and E. M manufactured therapeutic devices invented or developed by T, and P and E marketed such devices.
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Petitioners (T and his wife) were the sole and equal stockholders in three corporations, M, P, and E. M manufactured therapeutic devices invented or developed by T, and P and E marketed such devices. As a result of an informal arrangement the entire business operation of E was taken over by P as of the close of their fiscal year ending Nov. 30, 1963. Thereafter all selling was carried on by P. In connection with the unification, some $ 120,000 was distributed to T and his wife. Held: In the circumstances of this case there was a reorganization under sec. 368(a)(1)(D), and the distributions…
1Opinion of the Court
OPINION
Baum, Judge:
Petitioner Mark E. DeGroff is an inventor who has been engaged in the development and exploitation of therapeutic devices. The first such device of any consequence was the so-called Med-colator, which was marketed by a partnership in which DeGroff and his wife each had a 50-percent interest. In 1955 he invented another device named the Medco-sonlator, and in that year three corporations were organized, the stock in each of which was owned equally by both spouses. One was a manufacturing corporation (Medco Mfg.) which produced the Medcolator, the Medco-sonlator, and various…
2Cases cited25 opinions
- Helvering v. RankinSupreme Court of the United States · 1935
- Commissioner v. GordonSupreme Court of the United States · 1968
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- Acer Realty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1942
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3Cited by16 opinions
- Atlas Tool Co. v. CommissionerUnited States Tax Court · 1978
- Mark E. Degroff and Loveta S. Degroff v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Telephone Answering Service Co. v. CommissionerUnited States Tax Court · 1974
- Capital Sales, Inc. v. CommissionerUnited States Tax Court · 1978
- Iver W. And Faith S. Swanson v. United States of America, Iver W. Swanson v. United StatesCourt of Appeals for the Ninth Circuit · 1973
11 more not listed; retrieve them via the Exa API.