W. & B. Liquidating Corp. v. Commissioner
United States Tax Court
Petitioner's machine shop was damaged by fire on March 2, 1972. Petitioner, an accrual basis corporation, contracted with Conlon to reconstruct the shop. On May 9, petitioner adopted a plan of complete liquidation under sec. 337. On May 31, petitioner sold all of its assets to Syracuse China Corp., which assumed petitioner's liabilities.
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Petitioner's machine shop was damaged by fire on March 2, 1972. Petitioner, an accrual basis corporation, contracted with Conlon to reconstruct the shop. On May 9, petitioner adopted a plan of complete liquidation under sec. 337. On May 31, petitioner sold all of its assets to Syracuse China Corp., which assumed petitioner's liabilities. The sale included petitioner's right to an agreed $ 157,462 of fire insurance proceeds and its right to have Conlon complete the reconstruction, and Syracuse assumed the obligation to pay Conlon. At the time, $ 43,007 of the work had been completed and…
1Opinion of the Court
Hall, Judge:
Respondent determined a $35,563.16 deficiency in petitioner W. & B. Liquidating Corp.’s income tax for its taxable year ended June 30, 1972. Because W. & B. Liquidating Corp. was dissolved in 1973, respondent determined that petitioners in docket No. 10688-75 were liable as transferees for W. & B. Liquidating Corp.’s asserted income tax deficiency. Petitioners in docket No. 10688-75 have conceded that they are transferees of W. & B. Liquidating Corp. The sole issue remaining is whether W. & B. Liquidating Corp. must recognize the income which it realized through the involuntary…
2Cases cited7 opinions
- Central Tablet Manufacturing Co. v. United StatesSupreme Court of the United States · 1974
- 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
- Estate of Johnston v. CommissionerUnited States Tax Court · 1968
- In Re Goodman's Estate. Goodman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Ft. Hamilton Manors, Inc. v. CommissionerUnited States Tax Court · 1969
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3Cited by1 opinion
- W. & B. Liquidating Corp. v. CommissionerUnited States Tax Court · 1979