Legal Opinion

Auto Finance Co. v. Commissioner

United States Tax Court

Decided June 17, 1955No. Docket No. 52753Published

Petitioner was the controlling stockholder of two automobile dealer corporations. As part of a plan to dispose of its entire interest in each company at its book value, petitioner caused each company to distribute a preferred stock dividend of a total par value about equal to its accumulated earnings or profits.

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Petitioner was the controlling stockholder of two automobile dealer corporations. As part of a plan to dispose of its entire interest in each company at its book value, petitioner caused each company to distribute a preferred stock dividend of a total par value about equal to its accumulated earnings or profits. At each closing transaction at which it disposed of its entire interest in each company, petitioner's common stock was purchased by minority stockholders and others, and its preferred stock of one company was redeemed and that of the other was in part redeemed and in part transferred…

1Opinion of the Court

Auto Finance Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Auto Finance Co. v. Commissioner

Docket No. 52753

United States Tax Court

24 T.C. 416; 1955 U.S. Tax Ct. LEXIS 168;

June 17, 1955, Filed

Decision will be entered under Rule 50.

Petitioner was the controlling stockholder of two automobile dealer corporations. As part of a plan to dispose of its entire interest in each company at its book value, petitioner caused each company to distribute a preferred stock dividend of a total par value about equal to its accumulated earnings or profits. At each closing transaction at…

2Cases cited6 opinions

  1. Boyle v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
  2. Zenz v. QuinlivanCourt of Appeals for the Sixth Circuit · 1954
  3. Chamberlin v. CommissionerUnited States Tax Court · 1952
  4. Marie W. F. Nugent-Head Trust v. CommissionerUnited States Tax Court · 1951
  5. United Nat'l Corp. v. CommissionerUnited States Tax Court · 1943

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