Legal Opinion

Bixby v. Commissioner

United States Tax Court

Decided August 10, 1972No. Docket Nos. 4085-65, 5104-65, 5105-65, 6221-65 -- 6239-65, 5787-66, 5788-66, 5789-66Published

1. Petitioner Converse Rubber Corp. caused certain Bermuda trusts to be interposed in a transaction between itself and a seller of the assets of another corporation, Tyer. In form, the seller sold the assets to Bermuda trusts for x dollars and the trusts resold the assets to petitioner for x + y dollars; and y dollars was paid to the trusts in long-term highly subordinated notes.

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1. Petitioner Converse Rubber Corp. caused certain Bermuda trusts to be interposed in a transaction between itself and a seller of the assets of another corporation, Tyer. In form, the seller sold the assets to Bermuda trusts for x dollars and the trusts resold the assets to petitioner for x + y dollars; and y dollars was paid to the trusts in long-term highly subordinated notes. The accounts receivable of Tyer, which were guaranteed by Tyer, were entered on petitioner's books at face value. Held, the three-party purchase transaction was a sham. In substance, petitioner purchased the assets…

1Opinion of the Court

Mark Bixby and Hudythe Bixby, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Bixby v. Commissioner

Docket Nos. 4085-65, 5104-65, 5105-65, 6221-65 -- 6239-65, 5787-66, 5788-66, 5789-66

United States Tax Court

58 T.C. 757; 1972 U.S. Tax Ct. LEXIS 75;

August 10, 1972, Filed

Decisions in all dockets will be entered under Rule 50.

1. Petitioner Converse Rubber Corp. caused certain Bermuda trusts to be interposed in a transaction between itself and a seller of the assets of another corporation, Tyer. In form, the seller sold the assets to Bermuda trusts for x dollars and the trusts…

2Cases cited82 opinions

  1. Helvering v. HorstSupreme Court of the United States · 1940
  2. Commissioner v. TowerSupreme Court of the United States · 1946
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. Corliss v. BowersSupreme Court of the United States · 1930
  5. Knetsch v. United StatesSupreme Court of the United States · 1960

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