Legal Opinion

McDonald v. Commissioner

United States Tax Court

Decided September 20, 1961No. Docket Nos. 76938-76943Published

Corporation was liquidated and was entitled to nonrecognition of gain or loss under section 337(a), 1954 Code. It, however, was required to pay Louisiana State income taxes in a substantial amount arising out of and allocable to gains from the sale of real estate, with respect to which it was entitled to nonrecognition of gains under the Federal income tax laws. Respondent disallowed the deduction of Louisiana State income taxes.

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Corporation was liquidated and was entitled to nonrecognition of gain or loss under section 337(a), 1954 Code. It, however, was required to pay Louisiana State income taxes in a substantial amount arising out of and allocable to gains from the sale of real estate, with respect to which it was entitled to nonrecognition of gains under the Federal income tax laws. Respondent disallowed the deduction of Louisiana State income taxes. Respondent contends such taxes are allocable to a class of income wholly exempt from the taxes imposed by subtitle A of the Code and, therefore, nondeductible…

1Opinion of the Court

Bertha Gassie McDonald, Transferee, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

McDonald v. Commissioner

Docket Nos. 76938-76943

United States Tax Court

36 T.C. 1108; 1961 U.S. Tax Ct. LEXIS 70;

September 20, 1961, Filed

Decisions will be entered under Rule 50.

Corporation was liquidated and was entitled to nonrecognition of gain or loss under section 337(a), 1954 Code. It, however, was required to pay Louisiana State income taxes in a substantial amount arising out of and allocable to gains from the sale of real estate, with respect to which it was entitled to…

2Cases cited1 opinion

  1. McDonald v. CommissionerUnited States Tax Court · 1961

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