Barkley Co. of Arizona v. Commissioner
United States Tax Court
P Corp. was experiencing liquidity problems due to business difficulties and the death of B, its managing stockholder. A sister corporation of P, W, that held real estate for investment, was a likely source of the needed capital. W's stock had a stepped-up fair market value basis because it was held by B's estate.
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P Corp. was experiencing liquidity problems due to business difficulties and the death of B, its managing stockholder. A sister corporation of P, W, that held real estate for investment, was a likely source of the needed capital. W's stock had a stepped-up fair market value basis because it was held by B's estate. All of W's stock was contributed to P. W sold two parcels of land and distributed the proceeds to P. Subsequently, P and all of its subsidiaries, including W, adopted a plan of liquidation under sec. 337, I.R.C. 1954. W sold three more of its properties and distributed the proceeds…
1Opinion of the Court
BARKLEY COMPANY OF ARIZONA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Barkley Co. of Arizona v. Commissioner
Docket No. 6954-85.
United States Tax Court
T.C. Memo 1988-324; 1988 Tax Ct. Memo LEXIS 352; 55 T.C.M. (CCH) 1347; T.C.M. (RIA) 88324;
July 27, 1988.
P Corp. was experiencing liquidity problems due to business difficulties and the death of B, its managing stockholder. A sister corporation of P, W, that held real estate for investment, was a likely source of the needed capital. W's stock had a stepped-up fair market value basis because it was held by B's estate. All of W's…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- 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
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Burnside Veneer Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
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