Distributors Finance Corp. v. Commissioner
United States Tax Court
1. Petitioner purchased more than 80 per cent of the outstanding stock of X corporation and caused it to sell its operating assets to Y corporation in return for debentures of Y, the assumption of liabilities of X, and an adjustment in cash. Thereafter X was liquidated, petitioner receiving the debentures along with cash and other assets. Held, no gain was recognized on the liquidation of X under the provisions of section 112(b)(6), Internal Revenue Code.
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1. Petitioner purchased more than 80 per cent of the outstanding stock of X corporation and caused it to sell its operating assets to Y corporation in return for debentures of Y, the assumption of liabilities of X, and an adjustment in cash. Thereafter X was liquidated, petitioner receiving the debentures along with cash and other assets. Held, no gain was recognized on the liquidation of X under the provisions of section 112(b)(6), Internal Revenue Code. International Investment Corporation, 11 T. C. 678, affirmed 175 F. 2d 772 (C. A. 3); Tri-Lakes Steamship Co. v. Commissioner, 146 F. 2d…
1Opinion of the Court
Distributors Finance Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Distributors Finance Corp. v. Commissioner
Docket No. 27309
United States Tax Court
20 T.C. 768; 1953 U.S. Tax Ct. LEXIS 95;
July 6, 1953, Promulgated
Decision will be entered under Rule 50.
1. Petitioner purchased more than 80 per cent of the outstanding stock of X corporation and caused it to sell its operating assets to Y corporation in return for debentures of Y, the assumption of liabilities of X, and an adjustment in cash. Thereafter X was liquidated, petitioner receiving the debentures along with…
2Cases cited22 opinions
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. Ashland Oil & Refining Co.Court of Appeals for the Sixth Circuit · 1938
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