Verito v. Commissioner
United States Tax Court
Forty-five corporations adopted plans of complete liquidation on September 16, 1960. On September 20, 1960, the corporations made an offer to sell all of their assets. Their offer was accepted on September 26, 1960, by National Food Stores, Inc. On October 17, 1960, the closing of the sale took place and the corporations received the sales proceeds.
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Forty-five corporations adopted plans of complete liquidation on September 16, 1960. On September 20, 1960, the corporations made an offer to sell all of their assets. Their offer was accepted on September 26, 1960, by National Food Stores, Inc. On October 17, 1960, the closing of the sale took place and the corporations received the sales proceeds. Nineteen of these corporations, while awaiting the distribution of their assets, made temporary investments in various listed securities. Some of the securities were sold by the 19 corporations, resulting in the realization of gain. The 45…
1Opinion of the Court
OPINION
Fat, Judge:
The Commissioner determined deficiencies in income tax for the taxable period ended June 2, 1961, against 19 transferor corporations, in the aggregate amount of $22,296.54. These proceedings involve the liability of the petitioners as transferees of the assets of the aforementioned transferor corporations.1 The only issue to be decided is whether gain realized on certain sales of securities by the aforementioned transferor corporations should go unrecognized at the corporate level by virtue of section 337 of the Internal Eevenue Code of 1954.2
All of the facts have been…
Also in this document: Concurrence.
2Cases cited22 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Whipple v. CommissionerSupreme Court of the United States · 1963
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Commissioner v. BilderSupreme Court of the United States · 1962
17 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Estate of Munter v. CommissionerUnited States Tax Court · 1975
- Anders v. CommissionerUnited States Tax Court · 1967
- United States Holding Co. v. CommissionerUnited States Tax Court · 1965
- Midland-Ross Corporation, Transferee of Surface Combustion Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1973
- Miller v. CommissionerUnited States Tax Court · 1967
31 more not listed; retrieve them via the Exa API.