George L. Riggs, Inc. v. Commissioner
United States Tax Court
Held: Sec. 332, I.R.C. 1954, applicable to avoid recognition of gain on liquidation of subsidiary. Taxpayer owned 80 percent of the stock of the subsidiary on the date of the adoption of the plan of liquidation within the meaning of sec. 332(b).
1Opinion of the Court
George L. Riggs, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
George L. Riggs, Inc. v. Commissioner
Docket No. 8348-71
United States Tax Court
64 T.C. 474; 1975 U.S. Tax Ct. LEXIS 122;
June 24, 1975, Filed
Decision will be entered for the petitioner.
Held: Sec. 332, I.R.C. 1954, applicable to avoid recognition of gain on liquidation of subsidiary. Taxpayer owned 80 percent of the stock of the subsidiary on the date of the adoption of the plan of liquidation within the meaning of sec. 332(b).
Michael Steinberg, Joseph L. Cotter, and Edward L. Glazer, for the petitioner.
Barry J.…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Sandor v. CommissionerUnited States Tax Court · 1974
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Palmer v. CommissionerUnited States Tax Court · 1974
- J. C. Penney Co. v. CommissionerUnited States Tax Court · 1962
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