Wilson v. Commissioner
United States Tax Court
Petitioners, father and son, each owned 50 percent of the stock of two corporations, A company and B company. A company conducted a group insurance agency business; B company conducted a general insurance agency business. On November 1, 1957, A company transferred its group insurance business to B company in exchange for cash. Thereafter, A company collected its receivables and sold part of some stock it had bought as an investment.
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Petitioners, father and son, each owned 50 percent of the stock of two corporations, A company and B company. A company conducted a group insurance agency business; B company conducted a general insurance agency business. On November 1, 1957, A company transferred its group insurance business to B company in exchange for cash. Thereafter, A company collected its receivables and sold part of some stock it had bought as an investment. Prior to the end of 1957, A company distributed its assets, consisting of cash and the balance of the investment stock, to petitioners in exchange for their stock…
1Opinion of the Court
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners’ income taxes for the calendar year 1957 in the respective amounts set forth after their names:
Ralph 0. Wilson, Sr., and Tenna II. Wilson_$69, 539.28
Ralph 0. Wilson, Jr., and Janet M. Wilson_ 76,409. 59
After certain concessions made by the parties, the following issues remain to be decided:(1) Did the transfer of certain assets from Ralph C. Wilson Associates, Inc., to Ralph C. Wilson Agency, Inc., in exchange for cash, and the subsequent dissolution of Ralph C. Wilson Associates, Inc., constitute a corporate…
2Cases cited23 opinions
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- Lewis v. CommissionerUnited States Tax Court · 1960
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3Cited by37 opinions
- American Mfg. Co. v. CommissionerUnited States Tax Court · 1970
- Atlas Tool Co. v. CommissionerUnited States Tax Court · 1978
- Abegg v. CommissionerUnited States Tax Court · 1968
- Atlas Tool Co., Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7633-74). Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7634-74). Stephan Schaffan and Mildred Schaffan v. Commissioner of Internal Revenue, (Tax Court Docket No. 7635-74). Appeal of Atlas Tool Co., Inc., Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc., Stephan Schaffan and Mildred Schaffan, Atlas Tool Co., Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7633-74). Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7634-74). Stephan Schaffan and Mildred Schaffan v. Commissioner of Internal Revenue, (Tax Court Docket No. 7635-74). Appeal of Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- De Groff v. CommissionerUnited States Tax Court · 1970
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