Estate of Silverman v. Commissioner
United States Tax Court
Pursuant to a plan of merger, in 1982, P's exchanged their shares of stock in a State-chartered stock savings and loan association for passbook savings accounts and certificates of deposit in the acquiring federally chartered mutual savings and loan association. No part of the principal of the certificates of deposit could be withdrawn for 6 years. Ps did not report the gain realized on the transaction because they considered the merger to be a tax-free reorganization.
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Pursuant to a plan of merger, in 1982, P's exchanged their shares of stock in a State-chartered stock savings and loan association for passbook savings accounts and certificates of deposit in the acquiring federally chartered mutual savings and loan association. No part of the principal of the certificates of deposit could be withdrawn for 6 years. Ps did not report the gain realized on the transaction because they considered the merger to be a tax-free reorganization. In 1985, the U.S. Supreme Court decided Paulsen v. Commissioner,469 U.S. 131 (1985), holding that exchanges of this type did…
1Opinion of the Court
Estate of Mose Silverman, Deceased, Rose Silverman, Executrix, and Rose Silverman, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Silverman v. Commissioner
Docket No. 21209-88
United States Tax Court
98 T.C. 54; 1992 U.S. Tax Ct. LEXIS 7; 98 T.C. No. 6;
January 21, 1992, Filed
Decision will be entered for petitioners.
Pursuant to a plan of merger, in 1982, P's exchanged their shares of stock in a State-chartered stock savings and loan association for passbook savings accounts and certificates of deposit in the acquiring federally chartered mutual savings and loan association.…
2Cases cited28 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Rushing v. CommissionerUnited States Tax Court · 1969
- W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
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