Cronstroms Mfg., Inc. v. Commissioner
United States Tax Court
Held, that petitioners have established by a clear preponderance of the evidence that transfers of property made to them by another corporation at the time of their formation were not made with a major purpose of obtaining the surtax exemptions provided for in section 11(c) of the 1954 Code; and accordingly that respondent erred in denying to said petitioners, pursuant to section 1551 of the 1954 Code, the benefit of such exemptions for their taxable year 1954.
1Opinion of the Court
Pierce, Judge:
The respondent determined deficiencies in income tax against the petitioners, as follows:
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The cases were consolidated for trial.
The sole issue for decision, which is common to both cases, is whether each of the petitioners has established by a clear preponderance of the evidence (as provided in section 1551 of the 1951 Code), that the transfer of property to it by another corporation at the time of the petitioners’ formation was not made with a major purpose of securing the exemption from surtax provided by section 11 (c) of the 1954 Code.
Another issue raised by the…
2Cases cited3 opinions
- Coastal Oil Storage Company, and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Sno-Frost, Inc. v. CommissionerUnited States Tax Court · 1959
- Coastal Oil Storage Co. v. CommissionerUnited States Tax Court · 1956
3Cited by12 opinions
- Bush Hog Mfg. Co. v. CommissionerUnited States Tax Court · 1964
- The Louisville Store of Liberty, Ky., Inc. v. The United States, and Eight Related CasesUnited States Court of Claims · 1967
- Louisville Stone of Liberty, Ky., Inc. v. United StatesUnited States Court of Claims · 1967
- Beacon Auto Radiator Repair Co. v. CommissionerUnited States Tax Court · 1969
- New England Foundry Corp. v. CommissionerUnited States Tax Court · 1965
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