Legal Opinion

Bear v. Commissioner

United States Tax Court

Decided August 9, 1979No. Docket No. 7698-77, 7722-77Unpublished

Before liquidating Brookridge adopted a plan of complete liquidation under sec. 337, I.R.C. 1954. Brookridge's primary assets consisted of an inventory of real property divided into lots. In preparing to liquidate, Brookridge entered into a real estate sales contract with a third party whereby Brookridge, and its assignees, promised to sell its entire remaining inventory to an independent third party purchaser, over what could be 2 years.

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Before liquidating Brookridge adopted a plan of complete liquidation under sec. 337, I.R.C. 1954. Brookridge's primary assets consisted of an inventory of real property divided into lots. In preparing to liquidate, Brookridge entered into a real estate sales contract with a third party whereby Brookridge, and its assignees, promised to sell its entire remaining inventory to an independent third party purchaser, over what could be 2 years. Held: sale of inventory assets failed to qualify under sec. 337. Held further:Brookridge's liquidation failed to qualify under sec. 337 since contract to…

1Opinion of the Court

JOHN L. BEAR, Transferee, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; EDNA A. BEAR, Transferee, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bear v. Commissioner

Docket No. 7698-77, 7722-77.

United States Tax Court

T.C. Memo 1979-304; 1979 Tax Ct. Memo LEXIS 222; 38 T.C.M. (CCH) 1182; T.C.M. (RIA) 79304;

August 9, 1979, Filed

Before liquidating Brookridge adopted a plan of complete liquidation under sec. 337, I.R.C. 1954. Brookridge's primary assets consisted of an inventory of real property divided into lots. In preparing to liquidate, Brookridge entered into a real…

2Cases cited16 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Merrill v. CommissionerUnited States Tax Court · 1963
  3. Baird v. CommissionerUnited States Tax Court · 1977
  4. Margaret v. Dettmers, Estate of Herrick L. Johnston, Deceased, and Margaret v. Dettmers, Individually v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
  5. Estate of Johnston v. CommissionerUnited States Tax Court · 1968

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