Ingram-Richardson v. Commissioner
United States Tax Court
Transferor sold substantially all of its noncash assets to petitioner on November 17, 1965, pursuant to a plan of complete liquidation previously adopted in accordance with sec. 337, I.R.C. 1954. Held, that the fair market values of transferor's land improvements, buildings and machinery and equipment were $22,000, $355,000 and $72,708, respectively, as of November 17, 1965; an allocation of the lump sum sales price according to relative fair market values for the purpose of…
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Transferor sold substantially all of its noncash assets to petitioner on November 17, 1965, pursuant to a plan of complete liquidation previously adopted in accordance with sec. 337, I.R.C. 1954. Held, that the fair market values of transferor's land improvements, buildings and machinery and equipment were $22,000, $355,000 and $72,708, respectively, as of November 17, 1965; an allocation of the lump sum sales price according to relative fair market values for the purpose of determining transferor's ordinary gain under sec. 1245, I.R.C. 1954, made accordingly.
1Opinion of the Court
Ingram-Richardson, Inc. v. Commissioner.
Ingram-Richardson v. Commissioner
Docket No. 2079-69.
United States Tax Court
T.C. Memo 1972-157; 1972 Tax Ct. Memo LEXIS 99; 31 T.C.M. (CCH) 779; T.C.M. (RIA) 72157;
July 27, 1972
Transferor sold substantially all of its noncash assets to petitioner on November 17, 1965, pursuant to a plan of complete liquidation previously adopted in accordance with sec. 337, I.R.C. 1954.
Held, that the fair market values of transferor's land improvements, buildings and machinery and equipment were $22,000, $355,000 and $72,708, respectively, as of November 17, 1965; an…
2Cases cited16 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Chester D. Tripp, Chester D. Tripp, Surviving Spouse Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
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