Knowlton v. Commissioner
United States Tax Court
Petitioners received as part of a liquidating distribution from Dunmovin Corp. 24,950 shares of General Motors common stock, which Dunmovin had received after 1953 as a result of the court-ordered divestiture by E.I. duPont de Nemours & Co. of its interest in General Motors. Dunmovin acquired its interest in duPont prior to 1954. Held, the General Motors stock was, for purposes of sec. 333(e)(2), I.R.C. 1954, acquired by Dunmovin after Dec. 31, 1953.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax for the taxable years ending December 31, 1977, and December 31, 1978, of $61,924 and $63,281, respectively. In his answer, respondent asserted an increased deficiency for 1978 of $10,451. These deficiencies concern the "Nitrol issues” arising from respondent’s adjustments to petitioners’ Schedules C, and were the subject of a trial held before Judge Nims on December 12, 1983. In his amended answer, respondent alleged an additional increased deficiency for 1978 of $585,034.66, all of which concerns…
2Cases cited18 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Dixon v. United StatesSupreme Court of the United States · 1965
- United States v. E. I. Du Pont De Nemours & Co.Supreme Court of the United States · 1957
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Helvering v. HammelSupreme Court of the United States · 1941
13 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Sutton v. CommissionerUnited States Tax Court · 1985
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
- Dunn Trust v. CommissionerUnited States Tax Court · 1986
- National Sav. Life Ins. Co. v. CommissionerUnited States Tax Court · 1985
- Somerville v. United StatesUnited States Court of Claims · 1987
6 more not listed; retrieve them via the Exa API.