Legal Opinion

Cramer v. Commissioner

United States Tax Court

Decided June 29, 1953No. Docket Nos. 39447, 39448, 39449, 39450, 39451, 39452, 39453, 39454, 39455Published

Amounts equivalent to fair value received by stockholders from wholly owned corporation for stock of three other wholly owned corporations, held, on facts, to result in capital gain and not in a distribution substantially equivalent to a taxable dividend under applicable sections of Internal Revenue Code, including section 115 prior to 1950 amendments, and section 112 (c) (2). Rodman Wanamaker Trust, 11 T. C. 365, affd. (C. A. 2) 178 F. 2d 10, followed.

1Opinion of the Court

Emma Cramer, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent

Cramer v. Commissioner

Docket Nos. 39447, 39448, 39449, 39450, 39451, 39452, 39453, 39454, 39455

United States Tax Court

20 T.C. 679; 1953 U.S. Tax Ct. LEXIS 107;

June 29, 1953, Promulgated

Decisions will be entered under Rule 50.

Amounts equivalent to fair value received by stockholders from wholly owned corporation for stock of three other wholly owned corporations, held, on facts, to result in capital gain and not in a distribution substantially equivalent to a taxable dividend under applicable sections of Internal…

2Cases cited11 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  3. United States v. KatzSupreme Court of the United States · 1926
  4. Palmer v. CommissionerSupreme Court of the United States · 1937
  5. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950

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