Williamson v. Commissioner
United States Tax Court
1. Petitioners E and W each owned 50 of the 100 shares of the stock of C corporation and in 1948 they caused it to convey part of its assets to two newly formed corporations, O and P, in exchange for all of their capital stock.
Read the full summary
1. Petitioners E and W each owned 50 of the 100 shares of the stock of C corporation and in 1948 they caused it to convey part of its assets to two newly formed corporations, O and P, in exchange for all of their capital stock. E then surrendered 5 of his shares in C in exchange for 500 of the 1,000 shares of O and 1 of the 1,000 shares of P, and W simultaneously surrendered all of his shares in C in exchange for the remaining 500 shares in O and the remaining 999 shares of P. Held, the transaction failed to qualify as a tax-free reorganization under section 112 (g) (1) (D) and (h), I. R. C.…
1Opinion of the Court
OPINION.
Kern, Judge:
In 1948 the Edwards Cattle Company, a corporation the stock of which was equally owned by petitioners Williamson and Edwards, transferred certain assets to a newly formed corporation, Okeechobee Cattle Company, and also transferred certain other assets to a second newly formed corporation, Caloosa Ranch, Inc., in exchange for all the capital stock of these corporations. The Edwards Cattle Company retained some of its original assets so that all three corporations thereafter were able to conduct a cattle ranch business. The stock of Okeechobee was distributed equally to…
2Cases cited9 opinions
- Reis v. CommissionerUnited States Tax Court · 1942
- West Texas Refining & D. Co. v. Commissioner of Int. Rev.Court of Appeals for the Tenth Circuit · 1933
- Bullock v. CommissionerUnited States Tax Court · 1956
- Halliburton v. CommissionerCourt of Appeals for the Ninth Circuit · 1935
- Commissioner of Int. Rev. v. Schumacher Wall Bd. Corp.Court of Appeals for the Ninth Circuit · 1937
4 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Kattar v. CommissionerUnited States Tax Court · 1984
- Garcia v. CommissionerUnited States Tax Court · 1984
- Greenway v. CommissionerUnited States Tax Court · 1987
- Askew v. CommissionerUnited States Tax Court · 1985
- Sacco v. CommissionerUnited States Tax Court · 1988
2 more not listed; retrieve them via the Exa API.