Legal Opinion
William Liddon v. Commissioner of Internal Revenue, Maria Prothro Liddon v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided February 11, 1956No. 12398_1PublishedCited by 46 opinions
1Opinion of the Court
STEWART, Circuit Judge.
The sole issue to be determined on this review is whether amounts distributed to the petitioners in 1948 by a closely held corporation were taxable as ordinary income or as a long term capital gain. The Tax Court found that the amounts in question were distributed as “boot” pursuant to a plan of reorganization, having “the effect of the distribution of a taxable dividend” under section 112(c) (2) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 112(c) (2). The petitioners contend the distribution was made in complete liquidation of the corporation and that it should…
2Cases cited13 opinions
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
- Liddon v. CommissionerUnited States Tax Court · 1954
- United States v. Arcade Co.Court of Appeals for the Sixth Circuit · 1953
8 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- 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
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- Pridemark, Inc. v. CommissionerUnited States Tax Court · 1964
- Commissioner of Internal Revenue v. Walter L. And Helen MorganCourt of Appeals for the Third Circuit · 1961
41 more not listed; retrieve them via the Exa API.