Stevens Pass, Inc. v. Commissioner
United States Tax Court
Petitioner purchased 100 percent of the stock of the old company from its shareholders and liquidated the old company pursuant to sec. 332, I.R.C. 1954. Held, that petitioner may properly compute the basis of the assets received in the liquidation under sec. 334(b)(2). Held, further, that the basis allocated by petitioner to the tram equipment was proper. Held, further, that the useful life of ski lift No. 3 was 15 years.
1Opinion of the Court
Fat, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax for the fiscal years ended September 80, 1961, 1962, 1968, and 1964, in the amounts of $25,897.89, $38,566.82, $43,900.82, and $28,055.33, respectively.
The parties have stipulated as to certain items raised in the statutory notice of deficiency so that the issues remaining for determination are as follows:(1) Whether, upon the liquidation of its subsidiary, petitioner was entitled to the step-up in the basis of depreciable assets pursuant to section 334(b) (2) of the Internal Revenue Code of 1954.1(2) In the…
2Cases cited4 opinions
- Curry v. CommissionerUnited States Tax Court · 1965
- Dunn v. CommissionerUnited States Tax Court · 1964
- George C. Houck, Jr. v. H. I. Hinds, Individually and as Collector of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Murphy Logging Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1967
3Cited by9 opinions
- New England Tank Industries, Inc. v. CommissionerUnited States Tax Court · 1968
- Gulf Tel. Corp. v. CommissionerUnited States Tax Court · 1969
- Clayton v. CommissionerUnited States Tax Court · 1981
- Silverton v. CommissionerUnited States Tax Court · 1977
- Gulf Tel. Corp. v. CommissionerUnited States Tax Court · 1969
4 more not listed; retrieve them via the Exa API.