Webb v. Commissioner
United States Tax Court
In 1967 a controlled subsidiary corporation purchased from a decedent's estate a portion of the stock of the subsidiary's parent corporation in a transaction qualifying under sec. 303, I.R.C. 1954. The parent corporation was later liquidated and dissolved. Held, the parent corporation did not realize a dividend in 1967 from its subsidiary corporation under sec. 304(a)(2) and (b)( 2)(B), I.R.C. 1954, as a result of the purchase of its stock.
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In 1967 a controlled subsidiary corporation purchased from a decedent's estate a portion of the stock of the subsidiary's parent corporation in a transaction qualifying under sec. 303, I.R.C. 1954. The parent corporation was later liquidated and dissolved. Held, the parent corporation did not realize a dividend in 1967 from its subsidiary corporation under sec. 304(a)(2) and (b)( 2)(B), I.R.C. 1954, as a result of the purchase of its stock. Held, further, the parent corporation did not omit from its income tax return for 1967 a sum in excess of 25 percent of the gross income reported therein…
1Opinion of the Court
Featherston, Judge:
Pursuant to section 6901,2 respondent has detérmined that petitioners are liable as transferees for a deficiency of $216,161.48 in the 1967 Federal income tax of the Cecil M. Webb Holding Co., which was liquidated in 1971. The amounts of the transferee liabilities so determined in respect of each of the petitioners are as follows:
Helen M. Webb. $216,161.48
Charles M. Webb. 202,158.89
William C. Webb. 205,763.57
The following issues have been presented for decision:(1) Whether the proceeds of the sale of a parent corporation’s stock to a subsidiary corporation, which were…
2Cases cited22 opinions
- Knowlton v. MooreSupreme Court of the United States · 1900
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
- Maguire v. CommissionerSupreme Court of the United States · 1941
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3Cited by8 opinions
- Broadview Lumber Co. v. United StatesCourt of Appeals for the Seventh Circuit · 1977
- Continental Bankers Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Virginia Materials Corp. v. CommissionerUnited States Tax Court · 1976
- Broadview Lumber Co., Inc., Plaintiff-Appellant-Cross-Appellee v. United States of America, Defendant-Appellee-Cross-Appellant. Broadview Lumber Co., Inc., Successor-In-Interest by Statutory Merger to Allen County Lumber Co., Inc., Plaintiff-Appellant-Cross-Appellee v. United States of America, Defendant-Appellee-Cross-AppellantCourt of Appeals for the Seventh Circuit · 1977
- Helen M. Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1978
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