Legal Opinion

George L. Riggs, Inc. v. Commissioner

United States Tax Court

Decided June 24, 1975No. Docket No. 8348-71Published

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Sandor v. CommissionerUnited States Tax Court · 1974
  3. J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  4. Palmer v. CommissionerUnited States Tax Court · 1974
  5. J. C. Penney Co. v. CommissionerUnited States Tax Court · 1962

10 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API