Legal Opinion

Avco Mfg. Corp. v. Commissioner

United States Tax Court

Decided January 31, 1956No. Docket No. 45633Published

1. Held, the liquidation of Crosley Corporation in the fiscal year ended November 30, 1946, was not a tax-free transaction under section 112 (b) (6), I. R. C. 1939, and the loss sustained by petitioner thereon is recognizable. 2. Held, the transaction by which the assets of Lycoming Manufacturing Corporation were acquired by petitioner and subsequently transferred to Aviation Manufacturing Corporation was not one in which no gain or loss was recognizable under either section…

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1. Held, the liquidation of Crosley Corporation in the fiscal year ended November 30, 1946, was not a tax-free transaction under section 112 (b) (6), I. R. C. 1939, and the loss sustained by petitioner thereon is recognizable. 2. Held, the transaction by which the assets of Lycoming Manufacturing Corporation were acquired by petitioner and subsequently transferred to Aviation Manufacturing Corporation was not one in which no gain or loss was recognizable under either section 112 (g) (1) (C) or section 112 (b) (10) of the 1939 Code. 3. Held, Respondent erred in reducing the amount of loss…

1Opinion of the Court

Avco Manufacturing Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Avco Mfg. Corp. v. Commissioner

Docket No. 45633

United States Tax Court

25 T.C. 975; 1956 U.S. Tax Ct. LEXIS 281;

January 31, 1956, Filed

Decision will be entered under Rule 50.

1. Held, the liquidation of Crosley Corporation in the fiscal year ended November 30, 1946, was not a tax-free transaction under section 112 (b) (6), I. R. C. 1939, and the loss sustained by petitioner thereon is recognizable.

2. Held, the transaction by which the assets of Lycoming Manufacturing Corporation were acquired by…

Also in this document: Dissent · Murdock; Dissent · Pierce.

2Cases cited39 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Gregory v. HelveringSupreme Court of the United States · 1935
  3. Brown v. HelveringSupreme Court of the United States · 1934
  4. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  5. Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934

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