Legal Opinion
United States v. W. W. Marett and Ruth Marett
Court of Appeals for the Fifth Circuit
Decided November 7, 1963No. 20322PublishedCited by 38 opinions
1Opinion of the Court
TUTTLE, Chief Judge.
The United States appeals from a judgment in favor of the taxpayer for a refund of taxes illegally collected. The facts having all been stipulated, and thus not being in dispute, the sole question is whether the “spin off” 'of part of the activities previously carried on by Famous Foods, Inc. by the organization of a new corporation, Sunny South, and the distribution of the stock of Sunny South by Famous Foods to its stockholders was tax free within Section 355 of the 1954 Internal Revenue Code. 1
The material facts as stipulated and found by the District Court may be…
2Cases cited5 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Commissioner v. AckerSupreme Court of the United States · 1959
- Koshland v. HelveringSupreme Court of the United States · 1936
- United States v. CalamaroSupreme Court of the United States · 1957
- Coady v. CommissionerUnited States Tax Court · 1960
3Cited by38 opinions
- Minahan v. CommissionerUnited States Tax Court · 1987
- Estate of Boeshore v. CommissionerUnited States Tax Court · 1982
- Clair Smith v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Durbin Paper Stock Co. v. CommissionerUnited States Tax Court · 1983
- Foil v. CommissionerUnited States Tax Court · 1989
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