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
Helen M. Webb, Alleged Transferee, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Webb v. Commissioner
Docket Nos. 7004-74, 7012-74, 7056-74
United States Tax Court
67 T.C. 293; 1976 U.S. Tax Ct. LEXIS 19;
November 23, 1976, Filed
Decisions will be entered under Rule 155.
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…
Also in this document: Dissent.
2Cases cited26 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. DavisSupreme Court of the United States · 1970
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
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