Coca-Cola Bottling Co. v. Commissioner
United States Tax Court
1. Held, that petitioner is liable as a transferee of property of Crystal Coca-Cola Bottling Co. (dissolved), for unpaid deficiencies in the latter's income and excess profits taxes for the taxable periods involved, together with interest thereon; and that petitioner's liability as such transferee may be enforced by the Commissioner in the present proceeding, under section 311(a) of the 1939 Code and section 6901(a) of the 1954 Code. 2. Held, further, that whatever…
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1. Held, that petitioner is liable as a transferee of property of Crystal Coca-Cola Bottling Co. (dissolved), for unpaid deficiencies in the latter's income and excess profits taxes for the taxable periods involved, together with interest thereon; and that petitioner's liability as such transferee may be enforced by the Commissioner in the present proceeding, under section 311(a) of the 1939 Code and section 6901(a) of the 1954 Code. 2. Held, further, that whatever petitioner's contractual rights to indemnification from a former stockholder of Crystal may be, the Government is not required,…
1Opinion of the Court
Pierce, Judge:
The respondent determined that petitioner is liable as a transferee of assets of Crystal Coca-Cola Bottling Co. (dissolved), Tucson, Arizona, for the following deficiencies (together with interest thereon) which he determined in the income and excess profits taxes of the last-named company:
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The sole issue for decision is whether the petitioner is liable as such transferee.
All other issues raised by the pleadings have been eliminated. The parties have filed a written agreement which specifies how the amounts of the determined deficiencies and the amount of…
2Cases cited6 opinions
- Leach v. CommissionerUnited States Tax Court · 1953
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
- United States v. Genevieve RussellCourt of Appeals for the First Circuit · 1957
- United States v. FairallDistrict Court, S.D. New York · 1926
- Humbert v. CommissionerUnited States Board of Tax Appeals · 1931
1 more not listed; retrieve them via the Exa API.
3Cited by52 opinions
- Kreps v. CommissionerUnited States Tax Court · 1964
- Pierce v. CommissionerUnited States Tax Court · 1974
- Coca-Cola Bottling Company of Tucson, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- United States v. 58th Street Plaza Theatre, Inc.District Court, S.D. New York · 1968
- Adams v. CommissionerUnited States Tax Court · 1978
47 more not listed; retrieve them via the Exa API.