Callan v. Comm'r
United States Tax Court
A and B were each 50 percent stockholders of C corporation. In 1965 C made liquidating distributions of all of their assets to A and B in exchange for all of their capital stock. Thereafter C conducted no business whatever.
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A and B were each 50 percent stockholders of C corporation. In 1965 C made liquidating distributions of all of their assets to A and B in exchange for all of their capital stock. Thereafter C conducted no business whatever. In 1968 the Commissioner determined that C was liable for personal holding company tax for the taxable periods Mar. 1, 1964, to Feb. 28, 1965, and Mar. 1 to Mar. 12, 1965. As transferees of C's assets, A and B were liable for any deficiencies in personal holding company tax. On Mar. 27, 1968, in order to avoid liability for the tax by taking advantage of the statutory…
1Opinion of the Court
OPINION
Raum, Judge-.
The Commissioner determined deficiencies of $13,-943.28 and $671.86 in the income and personal holding company tax of Callan Investment Co. for the taxable year ended Febraury 28, 1965, and for the taxable period March 1, 1965, to March 12, 1965, respectively. He further determined that petitioners, as transferees of the assets of Callan Investment Co., were jointly and severally liable for the foregoing amounts, plus statutory interest. The only question for decision is whether payments of $19,918.98 and $959.82 made on March 27, 1968, by Callan Investment Co. qualify for…
2Cases cited25 opinions
- Hellmich v. HellmanSupreme Court of the United States · 1928
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Nicholson v. CommissionerUnited States Board of Tax Appeals · 1935
- Shoenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1935
- Foster v. United StatesSupreme Court of the United States · 1938
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3Cited by10 opinions
- Anderson v. CommissionerUnited States Tax Court · 1976
- L. C. Bohart Plumbing & Heating Co. v. CommissionerUnited States Tax Court · 1975
- Michael C. Callan and Thomas J. Callan, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
- Warren E. And Marion F. Fletcher v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Adams v. CommissionerUnited States Tax Court · 1979
5 more not listed; retrieve them via the Exa API.