Pridemark, Inc. v. Commissioner
United States Tax Court
1. Held, that certain 1958 and 1959 transactions of petitioners Pridemark, Inc., and Pridemark, Inc., of Connecticut, and their respective stockholders, did not effect complete liquidations of said corporations within the meaning of section 337 of the 1954 Code, because such transactions were incidental to a reorganization of the continuing business enterprise within the meaning of section 368 (a)(1)(F) of the Code.
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1. Held, that certain 1958 and 1959 transactions of petitioners Pridemark, Inc., and Pridemark, Inc., of Connecticut, and their respective stockholders, did not effect complete liquidations of said corporations within the meaning of section 337 of the 1954 Code, because such transactions were incidental to a reorganization of the continuing business enterprise within the meaning of section 368 (a)(1)(F) of the Code. Accordingly, held, further, that gains which said corporations realized from sales of assets during their fiscal periods ended in 1958, must be recognized for income tax purposes;…
1Opinion of the Court
Pridemark, Inc. (Formerly Prefab Homes and Suppliers, Inc.), et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Pridemark, Inc. v. Commissioner
Docket Nos. 93303, 93304, 93305, 93306, 93307
United States Tax Court
42 T.C. 510; 1964 U.S. Tax Ct. LEXIS 92;
June 15, 1964, Filed
Decisions will be entered under Rule 50.
1. Held, that certain 1958 and 1959 transactions of petitioners Pridemark, Inc., and Pridemark, Inc., of Connecticut, and their respective stockholders, did not effect complete liquidations of said corporations within the meaning of section 337 of the 1954 Code,…
2Cases cited31 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
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