Legal Opinion
Bryant Heater Company and Dresser Industries, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 14, 1956No. 12592PublishedCited by 13 opinions
1Opinion of the Court
STEWART, Circuit Judge.
Two separate questions are presented on this petition for review.
Petitioner Bryant Heater Company (hereinafter called “Bryant”) was a wholly owned subsidiary of petitioner Dresser Industries, Inc. (hereinafter called “Dresser”). In 1949 Bryant sold all its assets in an arms-length transaction to a third party for a total consideration of $6,100,000. The agreement of sale did not recite any allocation of the sales price among the various classes of assets sold. Bryant concededly realized a total profit upon the sale in an amount of more than $250,000. It has been…
2Cases cited5 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Thomas v. CommissionerCourt of Appeals for the Sixth Circuit · 1955
- Columbia Oil & Gas Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1941
- Commissioner of Internal Revenue v. Wayne Coal Mining Co. Commissioner of Internal Revenue v. Hillman Coal & Coke CoCourt of Appeals for the Third Circuit · 1954
- Shellabarger Grain Products Co. v. Com'r of Int. Rev.Court of Appeals for the Seventh Circuit · 1944
3Cited by13 opinions
- Vulcan Materials Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Thomas Crawley Davis and Grace Ethel Davis v. United StatesUnited States Court of Claims · 1961
- McCrory Corporation v. United StatesCourt of Appeals for the Second Circuit · 1981
- Canal-Randolph Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1977
- Davis v. United StatesUnited States Court of Claims · 1961
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