Legal Opinion

Whitson v. Rockwood

District Court, D. North Dakota

Decided December 14, 1960No. Civ. 223PublishedCited by 4 opinions

1Opinion of the Court

REGISTER, Chief Judge.

This action by plaintiffs is for the refund of income taxes allegedly overpaid for the year 1956.

The Court does not consider it necessary to state in detail the facts herein; a concise statement thereof is contained in the briefs submitted by respective counsel.

Section 337(a) of the 1954 Internal Revenue Code, 26 U.S.C.A. § 337(a), provides that if a corporation “adopts a plan of complete liquidation” on or after June 22, 1954, and within the 12 month period beginning on the date of the adoption of such plan all of the assets of the corporation (less assets retained to…

2Cases cited2 opinions

  1. United States v. PfisterCourt of Appeals for the Eighth Circuit · 1953
  2. Burnside Veneer Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948

3Cited by4 opinions

  1. Hollywood Baseball Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
  2. Adams v. CommissionerUnited States Tax Court · 1962
  3. Adams v. CommissionerUnited States Tax Court · 1962
  4. Intercounty Development Corp. v. CommissionerUnited States Tax Court · 1961

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