Haskell v. Commissioner
United States Board of Tax Appeals
A corporate distribution in liquidation was made to the petitioner in the taxable year. Held on the facts, that it was not made in complete liquidation of the corporation under section 115(c), Revenue Act of 1936, since not made in accordance with a plan specifying completion of liquidation within two years from the close of the year; held, further, that the corporate resolutions in later years did not effect, in the taxable year, a specification of the time limitation.
1Opinion of the Court
OPINION.
Disney:
This proceeding involves income taxes for the calendar year 1937 in the amount of $33,479.82, the entire deficiency determined. The question for examination is whether income received by the petitioner was distributed as a part of a complete liquidation by a corporation under section 115 (c) of the Revenue Act of 1936,1 *165or whether gain is to be recognized under section 117 (a) of the Revenue Act of 1936.2
The case was submitted upon stipulations, and exhibits attached and referred to therein. Certain objections to some of the exhibits were overruled, and we find the facts to be…
2Cited by4 opinions
- Harrell v. CommissionerUnited States Tax Court · 1944
- Haskell v. CommissionerUnited States Board of Tax Appeals · 1942
- Stavitsky v. CommissionerUnited States Tax Court · 1943
- W. Temple v. CommissionerUnited States Tax Court · 1946