Alexander v. Commissioner
United States Tax Court
In October 1966, X, a corporation, sold its assets to Z for cash and other consideration, including an agreement by Z to pay all of X's income tax liabilities. Most of the cash proceeds of the sale were distributed to A, and X was liquidated.
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In October 1966, X, a corporation, sold its assets to Z for cash and other consideration, including an agreement by Z to pay all of X's income tax liabilities. Most of the cash proceeds of the sale were distributed to A, and X was liquidated. Held: 1. A did not receive a liquidating distribution from X in 1966, within the meaning of sec. 331, I.R.C. 1954, in the form of the cancellation of indebtedness on an open account in the amount of $ 149,602; 2. A realized income in the amount of $ 42,500, under sec. 61, I.R.C. 1954, upon the receipt of that amount from Z pursuant to an agreement…
1Opinion of the Court
FeatheRSTON, Judge:
These proceedings involve deficiencies in individual income taxes and transferee liabilities for corporate income taxes determined by respondent as follows:
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For convenience, Morris Alexander will be referred to herein as petitioner, Perma-Line Midwest Corp. as Midwest, and Perma-Line Corp. of America as Perma-Line.
The following issues are presented for decision:(1) Whether petitioner’s liability of $149,602 on an open account with Perma-Line was canceled in connection with the liquidation of that corporation so that the amount of the account is taxable to him…
2Cases cited31 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Mysse v. CommissionerUnited States Tax Court · 1972
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
- O'Dwyer v. CommissionerUnited States Tax Court · 1957
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
26 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
- Merriam v. CommissionerUnited States Tax Court · 1995
- Illinois Masonic Home v. CommissionerUnited States Tax Court · 1989
- Boomershine v. CommissionerUnited States Tax Court · 1987
- Cullifer v. Comm'rUnited States Tax Court · 2014
14 more not listed; retrieve them via the Exa API.