Haserot v. Commissioner
United States Tax Court
Petitioner controlled corporations H, N, and G. Petitioner transferred to H all of his N and G stock and received a cash credit of $ 64,850 plus stock of H worth $ 48,640. Held on remand, the distribution of $ 64,850 was essentially equivalent to a dividend.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency in petitioners’1 1958 Federal income tax of $82,224.86. The principal ground for the deficiency was respondent’s claim that cash credited to petitioner, in a transaction involving the transfer of stock for stock and a cash credit, constituted dividend income.
On January 27, 1964, this Court filed its findings of fact and opinion in Henry McK. Haserot, 41 T.C. 562 (1964), holding that the cash credit was capital gain and entered its decision therein under Rule 50 on April 8, 1964.
Bespondent appealed tlxe decision to the U.S. Court of Appeals…
2Cases cited35 opinions
- Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Helvering v. HallockSupreme Court of the United States · 1940
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
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3Cited by32 opinions
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Quick Trust v. CommissionerUnited States Tax Court · 1970
- Lewis v. CommissionerUnited States Tax Court · 1966
- Niedermeyer v. CommissionerUnited States Tax Court · 1974
27 more not listed; retrieve them via the Exa API.