Rollestone Corp. v. Commissioner
United States Board of Tax Appeals
1. Distributions made during the taxable years were distributions in liquidation rather than dividends for income tax purposes, where prior to the taxable years the corporation had sold substantially all of its assets; thereafter it did not engage in its former business operations during the years in question; and its stockholders had agreed that it should be liquidated. 2. Previous distributions in 1922 and 1923 were ordinary dividends under section 201 of the Revenue Act…
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1. Distributions made during the taxable years were distributions in liquidation rather than dividends for income tax purposes, where prior to the taxable years the corporation had sold substantially all of its assets; thereafter it did not engage in its former business operations during the years in question; and its stockholders had agreed that it should be liquidated. 2. Previous distributions in 1922 and 1923 were ordinary dividends under section 201 of the Revenue Act of 1921 and did not serve to reduce the petitioners' basis for gain or loss on their stock. 3. The basis for gain or loss…
1Opinion of the Court
THE ROLLESTONE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
THE ROLLESTONE INVESTMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
THE FREELAND PROCESS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
THE MIDWEST INVESTMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
THE SOUTHERN INVESTMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
THE SOUTHWESTERN DEVELOPMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rollestone Corp. v. Commissioner
Docket Nos.…
2Cases cited16 opinions
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Guild v. CommissionerUnited States Board of Tax Appeals · 1930
- Gossett v. CommissionerUnited States Board of Tax Appeals · 1931
- McKinney v. CommissionerUnited States Board of Tax Appeals · 1935
- Simms v. CommissionerUnited States Board of Tax Appeals · 1933
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