Cohen v. Commissioner
United States Tax Court
Rucind, Inc., owned a tract of undeveloped land which it agreed to sell under contract dated Feb. 18, 1969. On Oct. 1, 1969, all the stockholders and directors of Rucind adopted a plan of complete liquidation pursuant to sec. 333, I.R.C. 1954, and all the stockholders filed proper elections under that section to have their gains treated in accordance with its provisions.
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Rucind, Inc., owned a tract of undeveloped land which it agreed to sell under contract dated Feb. 18, 1969. On Oct. 1, 1969, all the stockholders and directors of Rucind adopted a plan of complete liquidation pursuant to sec. 333, I.R.C. 1954, and all the stockholders filed proper elections under that section to have their gains treated in accordance with its provisions. On Oct. 3, 1969, the land, which was Rucind's only asset, was distributed in complete liquidation to the stockholders who, on Oct. 7, 1969, closed the aforearranged sale. Held, sale of the land must be considered as made by…
1Opinion of the Court
Aaron Cohen and Claire Cohen, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Cohen v. Commissioner
Docket Nos. 1291-73, 1292-73, 1293-73, 1294-73
United States Tax Court
63 T.C. 527; 1975 U.S. Tax Ct. LEXIS 196;
February 3, 1975, Filed
Decisions will be entered for the respondent.
Rucind, Inc., owned a tract of undeveloped land which it agreed to sell under contract dated Feb. 18, 1969. On Oct. 1, 1969, all the stockholders and directors of Rucind adopted a plan of complete liquidation pursuant to sec. 333, I.R.C. 1954, and all the stockholders filed proper elections under…
2Cases cited10 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Meyer's Estate v. Commissioner of Internal Revenue. (Three Cases)Court of Appeals for the Fifth Circuit · 1952
- Burke & Herbert Bank & Trust Co. v. CommissionerUnited States Tax Court · 1948
- Estate of Lamberth v. CommissionerUnited States Tax Court · 1958
- Estate of Stamos v. CommissionerUnited States Tax Court · 1970
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