Legal Opinion

Estate of Sidles v. Commissioner

United States Tax Court

Decided January 29, 1976No. Docket No. 6563-73Published

Decedent was the sole shareholder of a corporation. Prior to his death, a plan of complete liquidation under sec. 337, I.R.C. 1954, was adopted and the corporation's principal asset was sold pursuant to this plan.

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Decedent was the sole shareholder of a corporation. Prior to his death, a plan of complete liquidation under sec. 337, I.R.C. 1954, was adopted and the corporation's principal asset was sold pursuant to this plan. As of the date of decedent's death all that remained to be done under the plan was a corporate resolution to distribute and the distribution of the corporation's assets, subject to its liabilities, and the execution and filing of the articles of dissolution with the State. Held, on the date of his death the decedent possessed the right to receive the proceeds of the liquidation;…

1Opinion of the Court

Estate of Harry B. Sidles, Deceased, Daniel J. Monen, Jr., and Janice P. Sidles, Co-Executors, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Sidles v. Commissioner

Docket No. 6563-73

United States Tax Court

65 T.C. 873; 1976 U.S. Tax Ct. LEXIS 170;

January 29, 1976, Filed

Decision will be entered under Rule 155.

Decedent was the sole shareholder of a corporation. Prior to his death, a plan of complete liquidation under sec. 337, I.R.C. 1954, was adopted and the corporation's principal asset was sold pursuant to this plan. As of the date of decedent's death all that remained…

Also in this document: Concurrence; Dissent · Tannenwald; Dissent · Featherston.

2Cases cited33 opinions

  1. Rushing v. CommissionerUnited States Tax Court · 1969
  2. W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  3. Helvering v. Estate of EnrightSupreme Court of the United States · 1941
  4. Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
  5. Commissioner of Internal Revenue v. LindeCourt of Appeals for the Ninth Circuit · 1954

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