Olson v. Commissioner
United States Tax Court
1. Sidney, Philip, and Irving Olson are brothers. During 1961 and prior years, they and Albert Schultz were engaged in various capacities in the conduct of the business and affairs of a number of separate corporations and other business enterprises involved in the handling and sale of electronics merchandise at retail stores which are referred to collectively as the Olson Group.
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1. Sidney, Philip, and Irving Olson are brothers. During 1961 and prior years, they and Albert Schultz were engaged in various capacities in the conduct of the business and affairs of a number of separate corporations and other business enterprises involved in the handling and sale of electronics merchandise at retail stores which are referred to collectively as the Olson Group. Cleveland, which operated a retail store in Cleveland,Ohio, also owned all of the stock of Buffalo which operated a retail store in Buffalo, N.Y. In view of the labor difficulties with its employees, theretofore…
1Opinion of the Court
Withey, Judge:
The Commissioner has determined deficiencies in the income tax of the petitioners for 1961 as follows:
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Issues presented for determination are (1) whether the distribution by Olson Electronics of Cleveland, Inc., to its shareholders of all of the stock of its wholly 'owned subsidiary, Olson Electronics of Buffalo, Inc., qualified as a nontaxable transaction under the provisions of section 355 of the Internal Revenue Code of 1954 or whether it constituted a taxable dividend under sections 316 and 301 of the Code, (2) what was the fair market value of Olson Electronics…
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
- Zenz v. QuinlivanCourt of Appeals for the Sixth Circuit · 1954
- Badanes v. CommissionerUnited States Tax Court · 1962
8 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Joseph v. Rafferty v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1971
- Olson v. CommissionerUnited States Tax Court · 1967
- Tollefsen v. CommissionerUnited States Tax Court · 1969
- Dillin v. CommissionerUnited States Tax Court · 1971
- Olson v. CommissionerUnited States Tax Court · 1967
2 more not listed; retrieve them via the Exa API.