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