Bilar Tool & Die Corp. v. Commissioner
United States Tax Court
Friction occurred between petitioner's two equal stockholders which threatened disruption of its business. Petitioner adopted a plan for dividing the business between the two stockholders which involved the formation of a new corporation to which one-half of petitioner's assets were transferred in exchange for the stock of the new corporation, which was then exchanged for the 50 percent of petitioner's stock held by one of the stockholders.
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Friction occurred between petitioner's two equal stockholders which threatened disruption of its business. Petitioner adopted a plan for dividing the business between the two stockholders which involved the formation of a new corporation to which one-half of petitioner's assets were transferred in exchange for the stock of the new corporation, which was then exchanged for the 50 percent of petitioner's stock held by one of the stockholders. Held: The identified legal expenses incurred by petitioner in connection with the plan are deductible as ordinary and necessary business expenses under…
1Opinion of the Court
Bilar Tool & Die Corporation, Formerly Forway Tool & Die Co., Inc., a Michigan Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Bilar Tool & Die Corp. v. Commissioner
Docket No. 7411-72
United States Tax Court
62 T.C. 213; 1974 U.S. Tax Ct. LEXIS 110; 62 T.C. No. 24;
May 15, 1974, Filed
Decision will be entered under Rule 155.
Friction occurred between petitioner's two equal stockholders which threatened disruption of its business. Petitioner adopted a plan for dividing the business between the two stockholders which involved the formation of a new corporation to which…
Also in this document: Dissent.
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Woodward v. CommissionerSupreme Court of the United States · 1970
- United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
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