Honbarrier v. Commissioner
United States Tax Court
H was the sole shareholder of P. P was engaged in the business of hauling packaged freight in trucks. Its trucking operations were terminated in 1988. By 1990, P had sold its operating assets. P invested the proceeds from the sale of its operating assets in tax-exempt bonds and a municipal bond fund. C was a privately held trucking company that operated as a bulk carrier of chemicals.
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H was the sole shareholder of P. P was engaged in the business of hauling packaged freight in trucks. Its trucking operations were terminated in 1988. By 1990, P had sold its operating assets. P invested the proceeds from the sale of its operating assets in tax-exempt bonds and a municipal bond fund. C was a privately held trucking company that operated as a bulk carrier of chemicals. The majority of C's stock was owned by H. On Dec. 31, 1993, P was merged into C. Pursuant to the merger, H received 17,840 shares of C stock for his P stock. The value of the 17,840 shares was determined to be…
1Opinion of the Court
ARCHIE L. AND LOUISE B. HONBARRIER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent HONBARRIER, INC., FORMERLY CENTRAL TRANSPORT, INC., SUCCESSOR TO COLONIAL MOTOR FREIGHT LINE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Honbarrier v. Commissioner
Nos. 9053-97, 9054-97
United States Tax Court
115 T.C. 300; 2000 U.S. Tax Ct. LEXIS 69; 115 T.C. No. 23;
September 29, 2000, Filed
Decision will be entered for petitioner in docket No. 9054-97.
H was the sole shareholder of P. P was engaged in the
business of hauling packaged freight in trucks. Its trucking
operations were…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Helvering v. PriceSupreme Court of the United States · 1940
- Cortland Specialty Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
- Wortham MacHinery Company, a Wyoming Corporation v. The United States of AmericaCourt of Appeals for the Tenth Circuit · 1975
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