Hanna v. Commissioner
United States Tax Court
Losses on Sales or Exchanges Between Related Taxpayers -- Sec. 267, I.R.C. 1954. -- Held, no loss is allowable resulting from the redemption of stock by a corporation from a decedent's estate when all the stock of the corporation is owned by the estate and its beneficiaries who are sisters.
1Opinion of the Court
Estate of Ruth Hanna, Deceased, The National City Bank of Cleveland, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Hanna v. Commissioner
Docket No. 85667
United States Tax Court
37 T.C. 63; 1961 U.S. Tax Ct. LEXIS 52;
October 20, 1961, Filed
Decision will be entered under Rule 50.
Losses on Sales or Exchanges Between Related Taxpayers -- Sec. 267, I.R.C. 1954. -- Held, no loss is allowable resulting from the redemption of stock by a corporation from a decedent's estate when all the stock of the corporation is owned by the estate and its beneficiaries who are sisters.
Louis A.…
Also in this document: Concurrence.
2Cases cited4 opinions
- Lexmont Corp. v. CommissionerUnited States Tax Court · 1953
- Ingalls v. CommissionerUnited States Board of Tax Appeals · 1941
- Clark v. CommissionerCourt of Appeals for the Sixth Circuit · 1943
- Hanna v. CommissionerUnited States Tax Court · 1961