Atlas Tool Co. v. Commissioner
United States Tax Court
Corporation A and corporation B were each wholly owned by S. Corporation A was the principal purchaser of corporation B's production. In connection with a plan to terminate corporation B's activities and rely on foreign suppliers, corporation A acquired for cash corporation B's operating assets. Corporation B then distributed all of its remaining assets to S and dissolved.
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Corporation A and corporation B were each wholly owned by S. Corporation A was the principal purchaser of corporation B's production. In connection with a plan to terminate corporation B's activities and rely on foreign suppliers, corporation A acquired for cash corporation B's operating assets. Corporation B then distributed all of its remaining assets to S and dissolved. Corporation B's operating assets were acquired to ensure corporation A's supply of goods, but corporation A hoped not to have to use them. No active use of the assets was made for approximately 3 months. However, after…
1Opinion of the Court
Atlas Tool Co., Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Atlas Tool Co. v. Commissioner
Docket Nos. 7633-74, 7634-74, 7635-74
United States Tax Court
70 T.C. 86; 1978 U.S. Tax Ct. LEXIS 133;
April 27, 1978, Filed
Decisions will be entered under Rule 155.
Corporation A and corporation B were each wholly owned by S. Corporation A was the principal purchaser of corporation B's production. In connection with a plan to terminate corporation B's activities and rely on foreign suppliers, corporation A acquired for cash corporation B's operating assets. Corporation B then…
2Cases cited55 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. SternSupreme Court of the United States · 1958
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Bazley v. CommissionerSupreme Court of the United States · 1947
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
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