Legal Opinion

Shelton v. Commissioner

United States Tax Court

Decided August 16, 1995No. Docket No. 17901-92Published

On June 22, 1981, P's wholly owned corporation (J) sold stock of another corporation (E) to a third corporation (W) in exchange for a 20-year promissory note (Note). The stock of E served as collateral for the sale. Pursuant to the liquidation of J the note was distributed to P, and P reported the sale on the installment method. On Mar. 31, 1983, E sold its assets to an unrelated third party for cash and the assumption of liabilities.

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On June 22, 1981, P's wholly owned corporation (J) sold stock of another corporation (E) to a third corporation (W) in exchange for a 20-year promissory note (Note). The stock of E served as collateral for the sale. Pursuant to the liquidation of J the note was distributed to P, and P reported the sale on the installment method. On Mar. 31, 1983, E sold its assets to an unrelated third party for cash and the assumption of liabilities. On the same day, E and W adopted plans of liquidation pursuant to sec. 337, I.R.C. On Mar. 31, 1984, pursuant to the liquidations, the assets of E and W,…

1Opinion of the Court

JAMES M. SHELTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Shelton v. Commissioner

Docket No. 17901-92

United States Tax Court

105 T.C. 114; 1995 U.S. Tax Ct. LEXIS 46; 105 T.C. No. 10;

August 16, 1995, Filed

Decision will be entered for respondent as to the deficiency in tax and for petitioner as to the addition to tax.

On June 22, 1981, P's wholly owned corporation (J) sold stock of another corporation (E) to a third corporation (W) in exchange for a 20-year promissory note (Note). The stock of E served as collateral for the sale. Pursuant to the liquidation of J the note was…

2Cases cited30 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Griffiths v. CommissionerSupreme Court of the United States · 1939
  4. Pallottini v. CommissionerUnited States Tax Court · 1988
  5. Mailman v. CommissionerUnited States Tax Court · 1988

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