Phipps v. Commissioner
United States Tax Court
A parent corporation in a nontaxable reorganization liquidated five wholly owned subsidiaries, one of which had earnings and profits accumulated since March 1, 1913, in a comparatively small amount.
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A parent corporation in a nontaxable reorganization liquidated five wholly owned subsidiaries, one of which had earnings and profits accumulated since March 1, 1913, in a comparatively small amount. The other four had deficits in such earnings and profits in an aggregate amount much greater than the earnings and profits of the parent accumulated since March 1, 1913. Held, that a later distribution by the parent to its stockholders, including the petitioner, was, above the amount distributed from current earnings, distributed from capital. Commissioner v. Sansome, 60 Fed. (2d) 931; and Harter…
1Opinion of the Court
Margaret R. Phipps, Petitioner, v. Commissioner of Internal Revenue, Respondent
Phipps v. Commissioner
Docket No. 8854
United States Tax Court
8 T.C. 190; 1947 U.S. Tax Ct. LEXIS 303;
January 28, 1947, Promulgated
Decision will be entered under Rule 50.
A parent corporation in a nontaxable reorganization liquidated five wholly owned subsidiaries, one of which had earnings and profits accumulated since March 1, 1913, in a comparatively small amount. The other four had deficits in such earnings and profits in an aggregate amount much greater than the earnings and profits of the parent accumulated…
2Cases cited1 opinion
- Phipps v. CommissionerUnited States Tax Court · 1947