Abegg v. Commissioner
United States Tax Court
Abegg, a nonresident alien in 1957, liquidated Hevaloid, a wholly owned Delaware corporation, which was a personal holding company, and exchanged the property and cash he then received for all the stock of Suvretta, a Panama corporation, also a personal holding company.
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Abegg, a nonresident alien in 1957, liquidated Hevaloid, a wholly owned Delaware corporation, which was a personal holding company, and exchanged the property and cash he then received for all the stock of Suvretta, a Panama corporation, also a personal holding company. The name Suvretta was changed to Cresta on or about Mar. 5, 1958. In February 1958 he contributed additional securities to the capital of Suvretta having fair market values some in excess of his basis and some below his basis. No ruling under sec. 367 was requested. In 1958, 1959, and 1960 Cresta unsuccessfully sought…
1Opinion of the Court
Bruce, Judge:
These consolidated cases involve deficiencies determined as follows:
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Werner Abegg does not contest the deficiencies for 1959 or 1960 in docket No. 1570-62. Respondent concedes the addition to tax for 1959 for delinquent filing determined against Cresta Corp., S.A., in docket No. 1572-62. Other concessions were made by both parties which will be given effect under Rule 50.
The issues for decisions are (1) whether Cresta Corp., S.A., was engaged in trade or business in the United States in its fiscal years ended in 1958, 1959, and 1960; (2) whether the liquidation of…
2Cases cited36 opinions
- Dixon v. United StatesSupreme Court of the United States · 1965
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Frank v. CommissionerUnited States Tax Court · 1953
31 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Dean v. CommissionerUnited States Tax Court · 1971
- Werner Abegg v. Commissioner of Internal Revenue, Cresta Corporation, S.A., Transferee v. Commissioner of Intenal RevenueCourt of Appeals for the Second Circuit · 1970
- Lessinger v. CommissionerUnited States Tax Court · 1985
- International Tel. & Tel. Corp. etc. v. CommissionerUnited States Tax Court · 1981
- Malmstedt v. CommissionerCourt of Appeals for the Fourth Circuit · 1978
25 more not listed; retrieve them via the Exa API.