Ramm v. Commissioner
United States Tax Court
Petitioners, who collectively owned 50 percent of the shares of a subch. S corporation engaged in a ranching operation, had claimed on their individual tax returns investment tax credits on certain assets purchased by the corporation.
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Petitioners, who collectively owned 50 percent of the shares of a subch. S corporation engaged in a ranching operation, had claimed on their individual tax returns investment tax credits on certain assets purchased by the corporation. The corporation was liquidated under sec. 333, I.R.C. 1954, and those assets were distributed to the shareholders before the expiration of the holding period required by sec. 46. Petitioners thereafter used the assets received in a ranching business, but they operated independently from the other shareholders, who also used their property received in liquidation…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency of $4,790 in petitioners’ Federal income tax for the year 1974. The only issue presented for decision is whether petitioners, former shareholders of an electing small business corporation under section 1371,1 must recapture upon liquidation of the corporation certain investment tax credits allowed to them under section 48(e).
This case was submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and joint exhibits are incorporated herein by this reference. The pertinent facts are…
2Cases cited4 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
- Baker v. United StatesDistrict Court, W.D. Texas · 1975
3Cited by10 opinions
- Charles L. Long and Ruth S. Long v. United StatesCourt of Appeals for the Sixth Circuit · 1981
- Borgic v. CommissionerUnited States Tax Court · 1986
- Gorton v. CommissionerUnited States Tax Court · 1985
- Siller Bros. v. CommissionerUnited States Tax Court · 1987
- Borgic v. CommissionerUnited States Tax Court · 1986
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