Taylor Oil & Gas Co. v. Commissioner
United States Board of Tax Appeals
The sale herein is held to have been a sale of assets of a corporation in dissolution, and not a sale of property of the individual stockholders.
1Opinion of the Court
*615OPINION.
Love:
Admittedly, an attempt was made to avoid the accrual of a tax to the Gas Company on the sale to the Magnolia Company. In our opinion it fell measurably short of success.
The negotiations preceding this transaction were begun some time in 1919. By December 5,1919, all the details and preliminaries had been arranged and agreed to and nothing remained to be done to conclude the transaction except the actual and legal transfer of title. The large amount of tax to be incurred by the corporation inspired an inquiry as to the manner in which it could be at least in part legally avoided,…
2Cases cited1 opinion
- Moody-Hormann-Boelhauwe v. Clinton Wire Cloth Co.Court of Appeals for the Fifth Circuit · 1917
3Cited by16 opinions
- Nace Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Kell v. CommissionerUnited States Board of Tax Appeals · 1934
- Conservative Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Liberty Service Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Mackay v. CommissionerUnited States Board of Tax Appeals · 1934
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