Legal Opinion

MacDonald v. Commissioner

United States Tax Court

Decided May 5, 1944No. Docket Nos. 905, 906Published

Petitioners, a marital community in the State of Washington, owned all of the stock of a corporation, Carter, MacDonald & Co., engaged principally in the insurance brokerage business.

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Petitioners, a marital community in the State of Washington, owned all of the stock of a corporation, Carter, MacDonald & Co., engaged principally in the insurance brokerage business. At a time when liabilities exceeded the value of tangible assets, the corporation was dissolved and its assets distributed to petitioners in return for their stock; and the assets were then transferred to D. K. MacDonald for the marital community and he from that date conducted an insurance business under the same name as the old corporation. The insurance business was personal in its nature and depended very…

1Opinion of the Court

D. K. MacDonald, Petitioner, v. Commissioner of Internal Revenue, Respondent. Elise C. MacDonald, Petitioner, v. Commissioner of Internal Revenue, Respondent

MacDonald v. Commissioner

Docket Nos. 905, 906

United States Tax Court

3 T.C. 720; 1944 U.S. Tax Ct. LEXIS 132;

May 5, 1944, Promulgated

Decisions will be entered under Rule 50.

Petitioners, a marital community in the State of Washington, owned all of the stock of a corporation, Carter, MacDonald & Co., engaged principally in the insurance brokerage business. At a time when liabilities exceeded the value of tangible assets, the corporation was…

2Cases cited7 opinions

  1. Burnet v. LoganSupreme Court of the United States · 1931
  2. Helvering v. SalvageSupreme Court of the United States · 1936
  3. Metropolitan Bank v. St. Louis Dispatch Co.Supreme Court of the United States · 1893
  4. In Re the Accounting of BrownNew York Court of Appeals · 1926
  5. MacDonald v. CommissionerUnited States Tax Court · 1944

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