American Range Lines, Inc. v. Commissioner
United States Tax Court
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
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Hawkins v. GlennSupreme Court of the United States · 1889
- The Evergreens v. NunanCourt of Appeals for the Second Circuit · 1944
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
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