Wichita Terminal Elevator Co. v. Commissioner
United States Tax Court
On the record it is held that the sale and conveyance of certain properties of the corporate petitioner by a liquidating agent immediately after its dissolution became effective was a sale by or for account of such petitioner and the latter is liable for income tax on the gain realized.
1Opinion of the Court
OPINION.
Leecii, Judge:
Although petitioner asks redetermination of deficiencies in income and excess profits taxes for two years prior to the year in which the transaction here questioned took place, the parties are agreed that the sole question presented is whether the sale of the elevator properties was in fact made by petitioner and the gain so taxable, or by its stockholders and the consequent gain taxable to them. The effect of this transaction upon the income taxes of 1943 results from the fact that petitioner reported no gain to it from the sale of these properties, but instead reported…
2Cases cited5 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Fairfield Steamship Corp. v. CommissionerUnited States Tax Court · 1945
- Indianapolis & Cincinnati Traction Co. v. MonfortIndiana Court of Appeals · 1923
- Short v. Philadelphia, Baltimore & Washington RailroadSuperior Court of Delaware · 1908
- Moore v. GiffenCalifornia Court of Appeal · 1930
3Cited by24 opinions
- Brooks v. CommissionerUnited States Tax Court · 1984
- Gregory W. McKay v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- Stoumen v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Streber v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
- Michael v. Frierdich and Connie J. Frierdich v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
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