Byrne v. Commissioner
United States Tax Court
Petitioners were shareholders of X corporation, which owned an office building. On June 6, 1969, the president of X, who was also a shareholder, met with one of the other shareholders to discuss the liquidation of X in kind and sent a memorandum of that meeting to the other shareholders. On June 23, 1969, all the shareholders met and agreed to proceed promptly with the liquidation.
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Petitioners were shareholders of X corporation, which owned an office building. On June 6, 1969, the president of X, who was also a shareholder, met with one of the other shareholders to discuss the liquidation of X in kind and sent a memorandum of that meeting to the other shareholders. On June 23, 1969, all the shareholders met and agreed to proceed promptly with the liquidation. On Dec. 31, 1969, X was liquidated and its assets were transferred to the shareholders, who thereafter held the property as partners. Held, there was not "a written contract for the acquisition of [sec. 1250]…
1Opinion of the Court
Matthew V. Byrne and Elvira C. Byrne, Petitioners v. Commissioner of Internal Revenue, Respondent; Gordon P. Schopfer and Rhonda F. Schopfer, Petitioners v. Commissioner of Internal Revenue, Respondent
Byrne v. Commissioner
Docket Nos. 3315-74, 3316-74
United States Tax Court
65 T.C. 473; 1975 U.S. Tax Ct. LEXIS 17;
December 3, 1975, Filed
Decisions will be entered under Rule 155.
Petitioners were shareholders of X corporation, which owned an office building. On June 6, 1969, the president of X, who was also a shareholder, met with one of the other shareholders to discuss the liquidation of X in…
2Cases cited12 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Schultz v. CommissionerUnited States Tax Court · 1968
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