Legal Opinion
Madison Square Garden Corp. v. Commissioner
Court of Appeals for the Second Circuit
Decided July 30, 1974No. Nos. 858, 1099, Dockets 73-2160, 73-2407PublishedCited by 3 opinions
1Opinion of the Court
J. JOSEPH SMITH, Circuit Judge:
These are cross-appeals from a decision by the Tax Court, 58 T.C. 619 (1972), Irene F. Scott, Judge, holding (1) that the taxpayer, Madison Square Garden Corporation (MSG), was entitled under 26 U.S.C. § 334(b)(2) to a stepped-up basis for assets acquired through a merger-liquidation of a controlled corporation, but (2) that it was limited in this step-up to 80.22% of the assets received since it controlled only that percentage of the acquired corporation’s stock at the time of the liquidation. We affirm on the Commissioner’s appeal of the first holding, but…
2Cases cited6 opinions
- 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
- Yoc Heating Corp. v. CommissionerUnited States Tax Court · 1973
- Kass v. CommissionerUnited States Tax Court · 1973
- Madison Square Garden Corp. v. CommissionerUnited States Tax Court · 1972
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Madison Square Garden Corporation v. Commissioner Of Internal RevenueCourt of Appeals for the Second Circuit · 1974
- Telephone Answering Service Co. v. CommissionerUnited States Tax Court · 1974
- Telephone Answering Service Co. v. CommissionerUnited States Tax Court · 1974