Legal Opinion

Pebble Springs Distilling Co. v. Commissioner

United States Tax Court

Decided October 29, 1954No. Docket No. 40519Published

During the course of a liquidation which commenced in 1948, petitioner sold all of its noninventory assets to a corporation wholly owned by its controlling stockholders. The new corporation had broad powers to carry on the same business as petitioner as well as to conduct a real estate and other businesses. It rented the property to various tenants and was still in existence at the time of the hearing.

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During the course of a liquidation which commenced in 1948, petitioner sold all of its noninventory assets to a corporation wholly owned by its controlling stockholders. The new corporation had broad powers to carry on the same business as petitioner as well as to conduct a real estate and other businesses. It rented the property to various tenants and was still in existence at the time of the hearing. The price at which the noninventory assets were sold was $ 551,428.54 less than their depreciated book value. Petitioner claimed a net operating loss on its return for the fiscal year ended…

1Opinion of the Court

Pebble Springs Distilling Co., Petitioner, v. Commissioner of Internal Revenue, Respondent

Pebble Springs Distilling Co. v. Commissioner

Docket No. 40519

United States Tax Court

23 T.C. 196; 1954 U.S. Tax Ct. LEXIS 58;

October 29, 1954, Filed

Decision will be entered for the respondent.

During the course of a liquidation which commenced in 1948, petitioner sold all of its noninventory assets to a corporation wholly owned by its controlling stockholders. The new corporation had broad powers to carry on the same business as petitioner as well as to conduct a real estate and other businesses. It rented…

2Cases cited13 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Heller v. CommissionerUnited States Tax Court · 1943
  3. Survaunt v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1947
  4. Heller v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
  5. Liddon v. CommissionerUnited States Tax Court · 1954

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