Tollefsen v. Commissioner
United States Tax Court
T owned all the stock in A corporation. A corporation was in turn the sole shareholder of B corporation. B corporation sold for cash all its assets and manufacturing rights within the continental United States to a party unrelated to T and became inactive. Thereafter, T immediately began making cash withdrawals from B corporation which were evidenced by non-interest-bearing "notes."
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T owned all the stock in A corporation. A corporation was in turn the sole shareholder of B corporation. B corporation sold for cash all its assets and manufacturing rights within the continental United States to a party unrelated to T and became inactive. Thereafter, T immediately began making cash withdrawals from B corporation which were evidenced by non-interest-bearing "notes." Held, the net withdrawals from B corporation during the year in issue were not bona fide loans to T but, as a result of T's control over A and B corporations, were constructive dividends to T from A corporation.
1Opinion of the Court
George R. Tollefsen and Margaret A. Tollefsen, Petitioners v. Commissioner of Internal Revenue, Respondent
Tollefsen v. Commissioner
Docket No. 1743-67
United States Tax Court
52 T.C. 671; 1969 U.S. Tax Ct. LEXIS 89;
July 24, 1969, Filed
Decision will be entered for the respondent.
T owned all the stock in A corporation. A corporation was in turn the sole shareholder of B corporation. B corporation sold for cash all its assets and manufacturing rights within the continental United States to a party unrelated to T and became inactive. Thereafter, T immediately began making cash withdrawals from B…
2Cases cited14 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Wiese v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- Meyer v. CommissionerUnited States Board of Tax Appeals · 1941
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