Legal Opinion

Rodman v. Commissioner

United States Tax Court

Decided October 21, 1971No. Docket No. 5251-69Published

Petitioner owned oil-producing properties and nonproducing properties. Petitioner also owned 100 percent of the stock of Petroleum and 80 percent of the stock of Oil. According to a prearranged plan, petitioner transferred his producing and nonproducing properties to Petroleum for additional stock of Petroleum.

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Petitioner owned oil-producing properties and nonproducing properties. Petitioner also owned 100 percent of the stock of Petroleum and 80 percent of the stock of Oil. According to a prearranged plan, petitioner transferred his producing and nonproducing properties to Petroleum for additional stock of Petroleum. Thereafter, petitioner and the 20-percent owners of Oil exchanged all of their stock in Petroleum and Oil for stock of Reading & Bates, an unrelated publicly held corporation. Petitioner conceded that his transfer of properties to Petroleum should be treated as a taxable sale to…

1Opinion of the Court

E. G. Rodman and Fay L. Rodman, Petitioners v. Commissioner of Internal Revenue, Respondent

Rodman v. Commissioner

Docket No. 5251-69

United States Tax Court

57 T.C. 113; 1971 U.S. Tax Ct. LEXIS 37; 41 Oil & Gas Rep. 256;

October 21, 1971, Filed

Decision will be entered under Rule 50.

Petitioner owned oil-producing properties and nonproducing properties. Petitioner also owned 100 percent of the stock of Petroleum and 80 percent of the stock of Oil. According to a prearranged plan, petitioner transferred his producing and nonproducing properties to Petroleum for additional stock of Petroleum.…

2Cases cited6 opinions

  1. Cook v. TaitSupreme Court of the United States · 1924
  2. Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
  3. Bar L Ranch, Inc., and in Intervention-Appellant v. Robert L. Phinney, United States of America, in Intervention-AppelleeCourt of Appeals for the Fifth Circuit · 1970
  4. Dellinger v. CommissionerUnited States Tax Court · 1959
  5. Estate of Mundy v. CommissionerUnited States Tax Court · 1961

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