Legal Opinion

Trianon Hotel Co. v. Commissioner

United States Tax Court

Decided April 30, 1958No. Docket Nos. 60338, 60339, 60341, 63700Published

Trianon Hotel Company acquired all of the outstanding stock of the Allis Hotel Corporation and liquidated the latter corporation about a year later, thereby acquiring the liquidated corporation's assets. Trianon distributed $ 2,342,925 in cash and notes to the shareholders of Allis Corporation in acquiring their stock.

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Trianon Hotel Company acquired all of the outstanding stock of the Allis Hotel Corporation and liquidated the latter corporation about a year later, thereby acquiring the liquidated corporation's assets. Trianon distributed $ 2,342,925 in cash and notes to the shareholders of Allis Corporation in acquiring their stock. Allis, Shanberg, and Woolf, on the date of the transfer of their Allis Corporation stock to Trianon, together owned approximately 82.57 per cent of the outstanding stock of Allis Corporation, and approximately 79.11 per cent of the outstanding stock of Trianon. Amounts…

1Opinion of the Court

Trianon Hotel Company, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent

Trianon Hotel Co. v. Commissioner

Docket Nos. 60338, 60339, 60341, 63700

United States Tax Court

30 T.C. 156; 1958 U.S. Tax Ct. LEXIS 201;

April 30, 1958, Filed

In Docket Nos. 60338, 60341, and 63700, decisions will be entered under Rule 50.

In Docket No. 60339, decision will be entered for petitioner.

Trianon Hotel Company acquired all of the outstanding stock of the Allis Hotel Corporation and liquidated the latter corporation about a year later, thereby acquiring the liquidated corporation's assets.…

2Cases cited14 opinions

  1. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
  2. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. Commissioner of Internal Revenue v. Ashland Oil & Refining Co.Court of Appeals for the Sixth Circuit · 1938
  4. Kanawha Gas & Utilities Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
  5. Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946

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