Legal Opinion

W. Temple v. Commissioner

United States Tax Court

Decided August 30, 1946No. Docket No. 1327Unpublished

Under the facts, held, a distribution on January 16, 1940 was not one in complete liquidation under section 115 (c), I.R.C., prior to the 1942 amendment, and the gain realized therefrom is taxable as ordinary gain.

1Opinion of the Court

W. T. Temple v. Commissioner.

W. Temple v. Commissioner

Docket No. 1327.

United States Tax Court

1946 Tax Ct. Memo LEXIS 91; 5 T.C.M. (CCH) 763; T.C.M. (RIA) 46210;

August 30, 1946

Under the facts, held, a distribution on January 16, 1940 was not one in complete liquidation under section 115 (c), I.R.C., prior to the 1942 amendment, and the gain realized therefrom is taxable as ordinary gain.

Albert W. Taber, Esq., and Charles L. Claunch, Esq., Chattanooga Bank Bldg., Chattanooga, Tenn., for the petitioner. S. Earl Heilman, Esq., and Frank M. Thompson, Esq., for the respondent.

ARNOLD

Memorandum…

2Cases cited1 opinion

  1. Haskell v. CommissionerUnited States Board of Tax Appeals · 1942

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