Vern Realty, Inc. v. Commissioner
United States Tax Court
On Feb. 15, 1968, petitioner's shareholders adopted a plan of complete liquidation. On Mar. 15, 1968, petitioner sold an office building and deposited the proceeds of the sale in a savings account maintained in petitioner's name. Nothing was done to distribute these funds to petitioner's shareholders until Mar. 13, 1969, when such funds were transferred to savings accounts opened for the shareholders.
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On Feb. 15, 1968, petitioner's shareholders adopted a plan of complete liquidation. On Mar. 15, 1968, petitioner sold an office building and deposited the proceeds of the sale in a savings account maintained in petitioner's name. Nothing was done to distribute these funds to petitioner's shareholders until Mar. 13, 1969, when such funds were transferred to savings accounts opened for the shareholders. Although petitioner owned an apartment building with a value approximately equal to a mortgage against it plus a debt to one of the shareholders, nothing was done to set this building apart for…
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency of $9,396.77 in petitioner’s Federal income tax for its taxable year ending June 30,1968. The only issue presented for decision is whether, within the meaning of section 337 (a) ,1 all of the assets of petitioner, less assets retained to meet claims, were distributed within 12 months after the adoption of a plan of complete liquidation.
FINDINGS OF FACT
Vern Realty, Inc. (hereinafter referred to as petitioner), is a liquidated Rhode Island corporation which formerly had its principal office at 812 Industrial Bank Building, Providence, R.I.…
2Cases cited23 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Mountain Water Co. v. CommissionerUnited States Tax Court · 1960
- Gensinger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- United States Holding Co. v. CommissionerUnited States Tax Court · 1965
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