Messer v. Commissioner
United States Tax Court
Tel-O-Tube Corp. was dissolved under New Jersey law in 1960, but retained inter alia four interest-bearing notes and an antitrust claim until July 1961. Held, that the corporation continued in existence as a taxable entity through Sept. 30, 1961, pursuant to sec. 1.6012-2(a)(2), Income Tax Regs., and is taxable on the interest income earned with respect to the notes for the period from Sept. 30, 1960, to Aug. 1, 1961, and on the proceeds from the settlement of the antitrust…
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Tel-O-Tube Corp. was dissolved under New Jersey law in 1960, but retained inter alia four interest-bearing notes and an antitrust claim until July 1961. Held, that the corporation continued in existence as a taxable entity through Sept. 30, 1961, pursuant to sec. 1.6012-2(a)(2), Income Tax Regs., and is taxable on the interest income earned with respect to the notes for the period from Sept. 30, 1960, to Aug. 1, 1961, and on the proceeds from the settlement of the antitrust claim. Held, further, that the petitioners, its shareholders, are liable as transferees of the assets of the corporation…
1Opinion of the Court
Sidney Messer, Transferee, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Messer v. Commissioner
Docket Nos. 6523-65, 6524-65, 6525-65
United States Tax Court
52 T.C. 440; 1969 U.S. Tax Ct. LEXIS 113;
June 16, 1969, Filed
Decisions will be entered under Rule 50.
Tel-O-Tube Corp. was dissolved under New Jersey law in 1960, but retained inter alia four interest-bearing notes and an antitrust claim until July 1961. Held, that the corporation continued in existence as a taxable entity through Sept. 30, 1961, pursuant to sec. 1.6012-2(a)(2), Income Tax Regs., and is taxable on the…
2Cases cited26 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Goodstein v. CommissionerUnited States Tax Court · 1958
- Lang v. CommissionerSupreme Court of the United States · 1938
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