Legal Opinion

H. H. Robertson Co. v. Commissioner

United States Tax Court

Decided October 10, 1972No. Docket No. 2587-70Published

1. T, a U.S. corporation, in anticipation of liquidating a wholly owned foreign corporation (R.H.), sought and obtained a ruling from the Commissioner under sec. 367 of the 1954 Code that the liquidation would be nonrecognizable under sec. 332, on condition that all of the earnings and profits of R.H. be distributed as a dividend to T upon liquidation of R.H.

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1. T, a U.S. corporation, in anticipation of liquidating a wholly owned foreign corporation (R.H.), sought and obtained a ruling from the Commissioner under sec. 367 of the 1954 Code that the liquidation would be nonrecognizable under sec. 332, on condition that all of the earnings and profits of R.H. be distributed as a dividend to T upon liquidation of R.H. The liquidation was consummated on Dec. 28, 1965. Prior thereto, on Dec. 22, 1964, R.H. had distributed to T as a dividend-in-kind certain shares of stock in a second-tier subsidiary having a basis of $ 251,650 and a fair market value at…

1Opinion of the Court

H. H. Robertson Company, Petitioner v. Commissioner of Internal Revenue, Respondent

H. H. Robertson Co. v. Commissioner

Docket No. 2587-70

United States Tax Court

59 T.C. 53; 1972 U.S. Tax Ct. LEXIS 45;

October 10, 1972, Filed

Decision will be entered under Rule 50.

1. T, a U.S. corporation, in anticipation of liquidating a wholly owned foreign corporation (R.H.), sought and obtained a ruling from the Commissioner under sec. 367 of the 1954 Code that the liquidation would be nonrecognizable under sec. 332, on condition that all of the earnings and profits of R.H. be distributed as a dividend to T…

2Cases cited26 opinions

  1. General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
  2. Biddle v. CommissionerSupreme Court of the United States · 1938
  3. American Chicle Co. v. United StatesSupreme Court of the United States · 1942
  4. American Mfg. Co. v. CommissionerUnited States Tax Court · 1970
  5. Steel Improv. & Forge Co. v. CommissionerUnited States Tax Court · 1961

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