Legal Opinion

American Range Lines, Inc. v. Commissioner

United States Tax Court

Decided November 8, 1951No. Docket No. 25160Published

1. Transfer of property of petitioner corporation simultaneously with payment by transferee to petitioner's shareholder held to result in capital gain to petitioner notwithstanding payment was not made to petitioner. 2. Lucille H. Rogers, 11 T. C. 435, revd. (C. A. 3) 180 F. 2d 720, held, further, not res judicata although facts were identical, parties not being the same or in privity.

1Opinion of the Court

American Range Lines, Inc. (Formerly American Range-Liberty Lines, Inc.), Petitioner, v. Commissioner of Internal Revenue, Respondent

American Range Lines, Inc. v. Commissioner

Docket No. 25160

United States Tax Court

17 T.C. 764; 1951 U.S. Tax Ct. LEXIS 45;

November 8, 1951, Promulgated

Decision will be entered for the respondent.

1. Transfer of property of petitioner corporation simultaneously with payment by transferee to petitioner's shareholder held to result in capital gain to petitioner notwithstanding payment was not made to petitioner.

2. Lucille H. Rogers, 11 T. C. 435, revd. (C. A. 3) 180…

2Cases cited18 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. Hawkins v. GlennSupreme Court of the United States · 1889
  4. The Evergreens v. NunanCourt of Appeals for the Second Circuit · 1944
  5. United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942

13 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API