Atlas Tool Co. v. Commissioner
United States Tax Court
Corporation A and corporation B were each wholly owned by S. Corporation A was the principal purchaser of corporation B's production. In connection with a plan to terminate corporation B's activities and rely on foreign suppliers, corporation A acquired for cash corporation B's operating assets. Corporation B then distributed all of its remaining assets to S and dissolved.
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Corporation A and corporation B were each wholly owned by S. Corporation A was the principal purchaser of corporation B's production. In connection with a plan to terminate corporation B's activities and rely on foreign suppliers, corporation A acquired for cash corporation B's operating assets. Corporation B then distributed all of its remaining assets to S and dissolved. Corporation B's operating assets were acquired to ensure corporation A's supply of goods, but corporation A hoped not to have to use them. No active use of the assets was made for approximately 3 months. However, after…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes in the following amounts:
Petitioner Docket TYE No. Deficiency
Atlas Tool Co., Inc .7633-74 June 30, 1969 $147,103.59
June 30, 1970 98,933.78
Atlas Tool Co., Inc., successor to Fletcher Plastics., Inc.. 7634-74 Nov. 30, 1968 14,985.42
Nov. 30, 1969 22,161.39
Nov. 30, 1970 1,238.66
Stephan Schaffan and Mildred Schaffan .7635-74 Dec. 31, 1970 232,121.36
After concessions by the parties, the following issues remain for our consideration:(1) Whether a corporate distribution received by petitioner Stephan Schaffan in 1970…
2Cases cited55 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. SternSupreme Court of the United States · 1958
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Bazley v. CommissionerSupreme Court of the United States · 1947
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
50 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Laure v. CommissionerUnited States Tax Court · 1978
- Lessinger v. CommissionerUnited States Tax Court · 1985
- Atlas Tool Co., Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7633-74). Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7634-74). Stephan Schaffan and Mildred Schaffan v. Commissioner of Internal Revenue, (Tax Court Docket No. 7635-74). Appeal of Atlas Tool Co., Inc., Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc., Stephan Schaffan and Mildred Schaffan, Atlas Tool Co., Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7633-74). Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7634-74). Stephan Schaffan and Mildred Schaffan v. Commissioner of Internal Revenue, (Tax Court Docket No. 7635-74). Appeal of Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Warsaw Photographic Associates, Inc. v. CommissionerUnited States Tax Court · 1985
- Appeal of George R. Laure and Esther L. Laure. W-L Molding Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
27 more not listed; retrieve them via the Exa API.