Peeler Realty Co. v. Commissioner
United States Tax Court
On Mar. 30, 1966, petitioner conveyed approximately 25,000 acres of lands to its shareholders as a nonliquidating distribution. In two separate sales the shareholders sold a few acres of such lands in October of that year, and the balance in November. Petitioner did not include the gains from these sales in its corporate tax return.
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On Mar. 30, 1966, petitioner conveyed approximately 25,000 acres of lands to its shareholders as a nonliquidating distribution. In two separate sales the shareholders sold a few acres of such lands in October of that year, and the balance in November. Petitioner did not include the gains from these sales in its corporate tax return. An appeal from the decision in this case lies solely to the Fifth Circuit, which held in Hines v. United States, 477 F.2d 1063 (C.A. 5, 1973), reversing 344 F.Supp. 1259 (N.D. Miss. 1972), that the gains from these sales cannot be imputed to petitioner unless it…
1Opinion of the Court
Peeler Realty Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Peeler Realty Co. v. Commissioner
Docket No. 2328-71
United States Tax Court
60 T.C. 705; 1973 U.S. Tax Ct. LEXIS 80; 60 T.C. No. 74;
August 14, 1973, Filed
Decision will be entered for the petitioner.
On Mar. 30, 1966, petitioner conveyed approximately 25,000 acres of lands to its shareholders as a nonliquidating distribution. In two separate sales the shareholders sold a few acres of such lands in October of that year, and the balance in November. Petitioner did not include the gains from these sales in its…
2Cases cited27 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. HorstSupreme Court of the United States · 1940
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
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