Colt's Mfg. Co. v. Commissioner
United States Tax Court
1. Held, when viewed in the light of all the facts and circumstances, the 120,000 shares of its own stock, which petitioner had acquired in May 1950, pursuant to a resolution adopted by its stockholders authorizing the directors "to purchase or otherwise acquire outstanding shares of the capital stock of the company and to hold, sell, exchange, transfer or retire said shares from time to time, to such an extent, in such manner and upon such terms as the directors may deem…
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1. Held, when viewed in the light of all the facts and circumstances, the 120,000 shares of its own stock, which petitioner had acquired in May 1950, pursuant to a resolution adopted by its stockholders authorizing the directors "to purchase or otherwise acquire outstanding shares of the capital stock of the company and to hold, sell, exchange, transfer or retire said shares from time to time, to such an extent, in such manner and upon such terms as the directors may deem advisable," and which shares were thereafter held in the treasury until canceled and retired on December 18, 1952, are…
1Opinion of the Court
BRUCE, Judge:
The respondent determined a deficiency in petitioner’s income tax for the taxable year 1952 in the amount of $39,227.88. In his deficiency notice respondent allowed a deduction for the additional Connecticut State corporation excise tax which resulted from respondent’s adjustment of petitioner’s net income. By amended answers respondent alleged error in the allowance of this deduction and claimed additional deficiencies in the amounts of $6,395.21 and $3,296.05, making the total amount in controversy $48,919.14.
The issues presented are:(1) Whether, in the computation of…
2Cases cited4 opinions
- Chesbro v. CommissionerUnited States Tax Court · 1953
- Helvering v. Edison Bros. Stores, Inc.Court of Appeals for the Eighth Circuit · 1943
- United States v. Anderson, Clayton & Co.Supreme Court of the United States · 1955
- Sandoval Zinc Co. v. CommissionerUnited States Tax Court · 1958
3Cited by8 opinions
- Dravo Corporation v. The United StatesUnited States Court of Claims · 1965
- Lutz v. CommissionerUnited States Tax Court · 1966
- Penn-Texas Corporation (Formerly Colt's Manufacturing Company) v. The United StatesUnited States Court of Claims · 1962
- Consolidated Industries, Inc. v. CommissionerUnited States Tax Court · 1984
- Japanese Trading Co. v. CommissionerUnited States Tax Court · 1966
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