South Lake Farms, Inc. v. Commissioner
United States Tax Court
1. Late in September 1956 purchasing corporation purchased all of the capital stock of old corporation for the purpose of dissolving it and immediately taking over its assets. Early in October 1956 and pursuant to a plan of dissolution and complete liquidation the old corporation distributed and transferred all of its assets to purchasing corporation without receiving any payment therefor and thereby was rendered without any assets.
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1. Late in September 1956 purchasing corporation purchased all of the capital stock of old corporation for the purpose of dissolving it and immediately taking over its assets. Early in October 1956 and pursuant to a plan of dissolution and complete liquidation the old corporation distributed and transferred all of its assets to purchasing corporation without receiving any payment therefor and thereby was rendered without any assets. Held, that the market value of an unharvested cotton crop and certain land preparation included in the assets distributed and transferred is not includible in the…
1Opinion of the Court
Withey, Judge:
The respondent has determined deficiencies in the income tax of petitioner South Lake Farms, Inc., of $35,029.52, $37,791.98, and $853,731.09 for the fiscal years ended April 30, 1955, and April 30, 1956, and the period beginning May 1 and ending October 3, 1956, respectively. The respondent has determined that petitioner South Lake Farms is liable as transferee of the assets of South Lake Farms, Inc., for the foregoing deficiencies in the income tax of the latter corporation.
The issues for determination in the case of South Lake Farms, Inc., are the correctness of the…
2Cases cited10 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Helvering v. EubankSupreme Court of the United States · 1941
- SoRelle v. CommissionerUnited States Tax Court · 1954
5 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Estate of Munter v. CommissionerUnited States Tax Court · 1975
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
- Commissioner of Internal Revenue v. South Lake Farms, Inc., Commissioner of Internal Revenue v. South Lake FarmsCourt of Appeals for the Ninth Circuit · 1963
- Tennessee Carolina Transp., Inc. v. CommissionerUnited States Tax Court · 1975
- Anders v. CommissionerUnited States Tax Court · 1967
22 more not listed; retrieve them via the Exa API.