J. C. Penney Co. v. Commissioner
United States Tax Court
Liquidation of Subsidiary -- Recognition of Gain -- Sec. 392 and Sec. 337, I.R.C. 1954. -- In 1954, J. C. Penney Building and Realty Corporation, a wholly owned subsidiary of J. C. Penney Company, sold part of its assets, then adopted a plan of complete liquidation and completely liquidated before January 1, 1955. Held: The gain on the sale is recognized.
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Liquidation of Subsidiary -- Recognition of Gain -- Sec. 392 and Sec. 337, I.R.C. 1954. -- In 1954, J. C. Penney Building and Realty Corporation, a wholly owned subsidiary of J. C. Penney Company, sold part of its assets, then adopted a plan of complete liquidation and completely liquidated before January 1, 1955. Held: The gain on the sale is recognized. Petitioner's contention that the recognition of gain depended on whether or not the sale was made prior to or following the adoption of the plan of liquidation rejected.
1Opinion of the Court
J. C. Penney Company, Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent
J. C. Penney Co. v. Commissioner
Docket No. 73872
United States Tax Court
37 T.C. 1013; 1962 U.S. Tax Ct. LEXIS 181;
March 6, 1962, Filed
Decision will be entered for the respondent.
Liquidation of Subsidiary -- Recognition of Gain -- Sec. 392 and Sec. 337, I.R.C. 1954. -- In 1954, J. C. Penney Building and Realty Corporation, a wholly owned subsidiary of J. C. Penney Company, sold part of its assets, then adopted a plan of complete liquidation and completely liquidated before January 1, 1955. Held: The…
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