Legal Opinion

Harrell v. Commissioner

United States Tax Court

Decided May 17, 1944No. Docket No. 2782Unpublished

Pursuant to advice and explanation of the 3-year statutory limitation, given to them by their tax consultant, all of the stockholders of Hazen, Trent & Harrell Co. adopted a plan to liquidate immediately in order to obtain the advantages of the provisions of section 115 (c) of the Internal Revenue Code. Due to illness and other circumstances, the company's secretary did not record the stockholders' action. Complete liquidation was accomplished in less than two years.

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Pursuant to advice and explanation of the 3-year statutory limitation, given to them by their tax consultant, all of the stockholders of Hazen, Trent & Harrell Co. adopted a plan to liquidate immediately in order to obtain the advantages of the provisions of section 115 (c) of the Internal Revenue Code. Due to illness and other circumstances, the company's secretary did not record the stockholders' action. Complete liquidation was accomplished in less than two years. Held, upon the facts, that a bona fide plan of liquidation was adopted under which the transfer of the property, thereunder was…

1Opinion of the Court

J. M. Harrell v. Commissioner.

Harrell v. Commissioner

Docket No. 2782.

United States Tax Court

1944 Tax Ct. Memo LEXIS 251; 3 T.C.M. (CCH) 635; T.C.M. (RIA) 44172;

May 17, 1944

Pursuant to advice and explanation of the 3-year statutory limitation, given to them by their tax consultant, all of the stockholders of Hazen, Trent & Harrell Co. adopted a plan to liquidate immediately in order to obtain the advantages of the provisions of section 115 (c) of the Internal Revenue Code. Due to illness and other circumstances, the company's secretary did not record the stockholders' action. Complete…

2Cases cited1 opinion

  1. Haskell v. CommissionerUnited States Board of Tax Appeals · 1942

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