Yoc Heating Corp. v. Commissioner
United States Tax Court
R corporation sought to purchase the assets of O corporation and transfer them to a newly organized subsidiary of R. O refused to sell its assets. R thereafter purchased more than 85 percent of O's stock and organized a new corporation, N. O then transferred to N all its assets subject to its liabilities, which N assumed.
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R corporation sought to purchase the assets of O corporation and transfer them to a newly organized subsidiary of R. O refused to sell its assets. R thereafter purchased more than 85 percent of O's stock and organized a new corporation, N. O then transferred to N all its assets subject to its liabilities, which N assumed. In consideration for the transfer, N issued 1 share of its stock to R in exchange for every 3 shares of O stock held by R. N also made cash payments to most of the minority shareholders of O. Held, N is entitled to a stepped-up basis in the assets it acquired from O. Held,…
1Opinion of the Court
Yoc Heating Corp. (formerly known as Nassau Utilities Fuel Corp.), Petitioner v. Commissioner of Internal Revenue, Respondent
Yoc Heating Corp. v. Commissioner
Docket Nos. 625-69, 5680-71
United States Tax Court
61 T.C. 168; 1973 U.S. Tax Ct. LEXIS 25; 61 T.C. No. 21;
November 7, 1973, Filed
Decisions will be entered under Rule 50.
R corporation sought to purchase the assets of O corporation and transfer them to a newly organized subsidiary of R. O refused to sell its assets. R thereafter purchased more than 85 percent of O's stock and organized a new corporation, N. O then transferred to N all its…
Also in this document: Dissent · Scott; Dissent · Quealy.
2Cases cited32 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- 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
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