Associates Inv. Co. v. Commissioner
United States Tax Court
Protective, a Nebraska corporation, was dissolved and during the 2-year period following its dissolution, its vice president executed consents which purported to extend the period for assessment of tax deficiencies for the years 1958 through 1962. The Nebraska Business Corporation Act, which is based on the Model Business Corporation Act, provides that upon dissolution, a corporation's existence ceases, except for certain limited purposes.
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Protective, a Nebraska corporation, was dissolved and during the 2-year period following its dissolution, its vice president executed consents which purported to extend the period for assessment of tax deficiencies for the years 1958 through 1962. The Nebraska Business Corporation Act, which is based on the Model Business Corporation Act, provides that upon dissolution, a corporation's existence ceases, except for certain limited purposes. Held, under Nebraska law, the execution of the consents during the post-dissolution period was authorized.
1Opinion of the Court
OPINION
Simpson, Judge:
The respondent determined that the petitioner was liable as transferee for deficiencies in the income tax of the Protective Life Insurance Co. as follows:
Year Deficiency
1958_$200, 589. 67
1959_ 156, 645. 21
1960_ 212, 785. 62
Year Deficiency
1961_$338,490.63
1962__ 76,142.43
1966_ 471. 28
The issues in this case have been severed, and the only issue to be decided herein is whether consents executed by an officer of Protective, subsequent to — but within 2 years after — its dissolution, were valid and extended tbe period of limitations on assessments against Protective.
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2Cases cited18 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Chicago Title & Trust Co. v. Forty-One Thirty-Six Wilcox Bldg. Corp.Supreme Court of the United States · 1937
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- Badger Materials, Inc. v. CommissionerUnited States Tax Court · 1963
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
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3Cited by10 opinions
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Great Falls Bonding Agency, Inc. v. CommissionerUnited States Tax Court · 1974
- Dillman v. CommissionerUnited States Tax Court · 1975
- Associates Inv. Co. v. CommissionerUnited States Tax Court · 1972
- Dillman v. CommissionerUnited States Tax Court · 1975
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