Alexander v. Commissioner
United States Tax Court
In October 1966, X, a corporation, sold its assets to Z for cash and other consideration, including an agreement by Z to pay all of X's income tax liabilities. Most of the cash proceeds of the sale were distributed to A, and X was liquidated.
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In October 1966, X, a corporation, sold its assets to Z for cash and other consideration, including an agreement by Z to pay all of X's income tax liabilities. Most of the cash proceeds of the sale were distributed to A, and X was liquidated. Held: 1. A did not receive a liquidating distribution from X in 1966, within the meaning of sec. 331, I.R.C. 1954, in the form of the cancellation of indebtedness on an open account in the amount of $ 149,602; 2. A realized income in the amount of $ 42,500, under sec. 61, I.R.C. 1954, upon the receipt of that amount from Z pursuant to an agreement…
1Opinion of the Court
Morris and Annette G. Alexander, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Alexander v. Commissioner
Docket Nos. 7389-70, 7668-70, 7669-70
United States Tax Court
61 T.C. 278; 1973 U.S. Tax Ct. LEXIS 15; 61 T.C. No. 30;
November 26, 1973, Filed
Decisions will be entered under Rule 50.
In October 1966, X, a corporation, sold its assets to Z for cash and other consideration, including an agreement by Z to pay all of X's income tax liabilities. Most of the cash proceeds of the sale were distributed to A, and X was liquidated. Held:
1. A did not receive a liquidating…
2Cases cited32 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Mysse v. CommissionerUnited States Tax Court · 1972
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
- O'Dwyer v. CommissionerUnited States Tax Court · 1957
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
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