Legal Opinion

Ludorff v. Commissioner

United States Board of Tax Appeals

Decided June 7, 1939No. Docket No. 89212Published

A corporation in which petitioners' decedent held stock made distributions in 1933 and 1934 in complete liquidation. Held, that the amount distributed in 1934 constitutes gain to the extent that it exceeds the stockholder's base after applying in reduction thereof the amount of the distributions made in 1933.

1Opinion of the Court

ALVINA LUDORFF AND EMMA C. MEISSNER, AS EXECUTRICES UNDER THE LAST WILL AND TESTAMENT OF ALBERT LUDORFF, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ludorff v. Commissioner

Docket No. 89212.

United States Board of Tax Appeals

40 B.T.A. 32; 1939 BTA LEXIS 905;

June 7, 1939, Promulgated

A corporation in which petitioners' decedent held stock made distributions in 1933 and 1934 in complete liquidation. Held, that the amount distributed in 1934 constitutes gain to the extent that it exceeds the stockholder's base after applying in reduction thereof the amount of the…

2Cases cited9 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  3. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  4. Burnet v. LoganSupreme Court of the United States · 1931
  5. Letts v. CommissionerUnited States Board of Tax Appeals · 1934

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