Rojas v. Commissioner
United States Tax Court
D and E are the transferees and former majority shareholders of S, a corporation that had been engaged in the business of farming row crops. S adopted a plan of complete liquidation and pursuant to that plan, distributed to its majority shareholders all its operating assets, including certain harvested and unharvested crops.
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D and E are the transferees and former majority shareholders of S, a corporation that had been engaged in the business of farming row crops. S adopted a plan of complete liquidation and pursuant to that plan, distributed to its majority shareholders all its operating assets, including certain harvested and unharvested crops. Prior to the liquidation, S had deducted, pursuant to sec. 162(a), I.R.C. 1954, expenses incurred in connection with the cost of cultivating these crops. Held, the tax-benefit rule does not require S to include in income the expenses deducted for materials and services…
1Opinion of the Court
OPINION
WHALEN, Judge:*
Respondent determined deficiencies in the Federal income tax of petitioner Schwartz Farms, Inc., in the following amounts:
TYE Jan. 31— Deficiency
1975. $1,782
1977. 742,222
1978. 284,256
Total. 1,028,260
Respondent also determined that petitioners, Dorothy Schwartz Rojas and the estate of Charles R. Schwartz, deceased, were liable for such amount as transferees.1
These cases were consolidated for trial, briefing, and opinion. After concessions, the only issue for decision is whether the tax-benefit rule requires Schwartz Farms, Inc., to report as income the amount which it…
2Cases cited11 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Nash v. United StatesSupreme Court of the United States · 1970
- Louis Spitalny and Betty Spitalny, His Wife v. United States of America, William Erdwurm and Bart F. Erdwurm, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Estate of Munter v. CommissionerUnited States Tax Court · 1975
6 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
- Estate of Mueller v. Comm'rUnited States Tax Court · 1993
- Rosenberg v. CommissionerUnited States Tax Court · 1991
- Schwartz Rojas v. CommissionerCourt of Appeals for the Ninth Circuit · 1990
- Gold Kist v. CommissionerUnited States Tax Court · 1995
10 more not listed; retrieve them via the Exa API.