Union Starch & Refining Co. v. Commissioner
United States Tax Court
Petitioner transferred 8,700 shares of the common stock of Sterling Drug Company, Inc., in exchange for 1,609 3/4 shares of its own stock owned by two minority stockholders. The transaction was initiated by the stockholders. Held, the transaction constituted a partial liquidation within the meaning of section 115 (c) and (i) of the 1939 Code, and no taxable gain was realized by petitioner.
1Opinion of the Court
Union Starch and Refining Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Union Starch & Refining Co. v. Commissioner
Docket No. 65357
United States Tax Court
31 T.C. 1041; 1959 U.S. Tax Ct. LEXIS 234;
February 25, 1959, Filed
Decision will be entered for the petitioner.
Petitioner transferred 8,700 shares of the common stock of Sterling Drug Company, Inc., in exchange for 1,609 3/4 shares of its own stock owned by two minority stockholders. The transaction was initiated by the stockholders. Held, the transaction constituted a partial liquidation within the meaning of…
2Cases cited5 opinions
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Allport v. CommissionerUnited States Tax Court · 1944
- United States v. Anderson, Clayton & Co.Supreme Court of the United States · 1955
- Lencard Corp. v. CommissionerUnited States Board of Tax Appeals · 1942
- Union Starch & Refining Co. v. CommissionerUnited States Tax Court · 1959