Baan v. Commissioner
United States Tax Court
Pacific corporation was engaged in the telephone business in California and other western States. It transferred to Northwest, a newly created subsidiary, the assets used in the telephone business conducted in Oregon, Washington, and Idaho. It thus became the owner of all of the Northwest stock which it subsequently distributed through the medium of short-term rights issued to its stockholders.
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Pacific corporation was engaged in the telephone business in California and other western States. It transferred to Northwest, a newly created subsidiary, the assets used in the telephone business conducted in Oregon, Washington, and Idaho. It thus became the owner of all of the Northwest stock which it subsequently distributed through the medium of short-term rights issued to its stockholders. Held, the transaction was a tax-free spin-off under section 355, I.R.C. 1954, and petitioner-stockholders who obtained Northwest stock by exercising their rights did not thereby realize taxable income…
1Opinion of the Court
Oscar E. Baan and Evelyn K. Baan, Petitioners, v. Commissioner of Internal Revenue, Respondent; Irving Gordon and Margaret Gordon, Petitioners, v. Commissioner of Internal Revenue, Respondent
Baan v. Commissioner
Docket Nos. 949-63, 3949-63
United States Tax Court
45 T.C. 71; 1965 U.S. Tax Ct. LEXIS 25;
October 19, 1965, Filed
Decision will be entered for the petitioners in docket No. 949-63.
Decision will be entered under Rule 50 in docket No. 3949-63.
Pacific corporation was engaged in the telephone business in California and other western States. It transferred to Northwest, a newly created…
2Cases cited11 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Choate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
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