Woodward Inv. Co. v. Commissioner
United States Board of Tax Appeals
In 1936 petitioner entered upon a plan of liquidation which was to be completed within two years. On December 31, 1936, in pursuance of the plan, petitioner distributed to its sole stockholder certain cash and other property, the total value of which was less than the cost basis of the shares of stock owned by the sole stockholder and she had no gain or loss from the liquidation in 1936. In 1937 and 1938 the liquidation of petitioner was completed and the sole stockholder…
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In 1936 petitioner entered upon a plan of liquidation which was to be completed within two years. On December 31, 1936, in pursuance of the plan, petitioner distributed to its sole stockholder certain cash and other property, the total value of which was less than the cost basis of the shares of stock owned by the sole stockholder and she had no gain or loss from the liquidation in 1936. In 1937 and 1938 the liquidation of petitioner was completed and the sole stockholder received a profit from the liquidation of her shares, which gain has been recognized for tax purposes. Held, that…
1Opinion of the Court
OPINION.
Black:
The Commissioner determined a deficiency of $5,397.43 in income tax against petitioner for the year 1936. The ground for the determination of the deficiency is stated in the deficiency notice as follows:
Your contention that, in the computation of the surtax on undistributed pmfits as provided in section 14 of the Revenue Act of 1936, you are' entitled to a credit for dividends paid of a portion of a distribution in liquidation in the amount of $112,800.00 is denied for the reason that under the provisions of section 27 (f) of the Revenue Act of 1936 this office considers that no…
2Cited by6 opinions
- Anderson v. CommissionerUnited States Tax Court · 1976
- Webb v. CommissionerUnited States Tax Court · 1977
- Henricksen v. BraicksCourt of Appeals for the Ninth Circuit · 1943
- Anderson v. CommissionerUnited States Tax Court · 1976
- Webb v. CommissionerUnited States Tax Court · 1977
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