Legal Opinion

Luckman v. Commissioner

United States Tax Court

Decided August 31, 1971No. Docket No. 3959-65Published

In determining the taxability of distributions by Rapid American Corp. (Rapid) to its shareholders, including petitioners, during its fiscal year ending January 1962. Held: 1. Rapid's deficit in earnings and profits as of July 31, 1961, may not be used to offset earnings and profits of corporations acquired by Rapid on July 31, 1961, under sec. 332, I.R.C. 1954. 2. Income recognized by Rapid in its fiscal years ending January 1961 and January 1962 from an installment sale…

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In determining the taxability of distributions by Rapid American Corp. (Rapid) to its shareholders, including petitioners, during its fiscal year ending January 1962. Held: 1. Rapid's deficit in earnings and profits as of July 31, 1961, may not be used to offset earnings and profits of corporations acquired by Rapid on July 31, 1961, under sec. 332, I.R.C. 1954. 2. Income recognized by Rapid in its fiscal years ending January 1961 and January 1962 from an installment sale completed in fiscal 1961 may not be disregarded in computing Rapid's earnings and profits for such years even though the…

1Opinion of the Court

Sid Luckman and Estelle Luckman, Petitioners v. Commissioner of Internal Revenue, Respondent

Luckman v. Commissioner

Docket No. 3959-65

United States Tax Court

56 T.C. 1216; 1971 U.S. Tax Ct. LEXIS 64;

August 31, 1971, Filed

Decision will be entered under Rule 50.

In determining the taxability of distributions by Rapid American Corp. (Rapid) to its shareholders, including petitioners, during its fiscal year ending January 1962. Held:

1. Rapid's deficit in earnings and profits as of July 31, 1961, may not be used to offset earnings and profits of corporations acquired by Rapid on July 31, 1961, under…

2Cases cited22 opinions

  1. Stein v. CommissionerUnited States Tax Court · 1956
  2. Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
  3. Lazarus I. Levine and Norman L. Marks, Executors of the Estate of Samuel Stein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
  4. Commissioner v. PhippsSupreme Court of the United States · 1949
  5. Wilson v. CommissionerUnited States Tax Court · 1966

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