Commercial Finance Co. v. Commissioner
United States Tax Court
Commercial Finance Company, a Colorado corporation, was dissolved in 1962, and all of its assets were distributed to its shareholders. Included in corporate assets were substantial debts due from the Estate of Gertrude Cullen, Deceased, the majority stockholder, some of which were secured by deeds of trust on business properties which were left to two relatives who were also entitled to her Commercial stock under her will.
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Commercial Finance Company, a Colorado corporation, was dissolved in 1962, and all of its assets were distributed to its shareholders. Included in corporate assets were substantial debts due from the Estate of Gertrude Cullen, Deceased, the majority stockholder, some of which were secured by deeds of trust on business properties which were left to two relatives who were also entitled to her Commercial stock under her will. Commercial, an accrual basis taxpayer, had regularly accrued interest on the deed of trust notes on its books and reported them for income tax purposes. The Estate, a cash…
1Opinion of the Court
Commercial Finance Company, et al. 1 v. Commissioner.
Commercial Finance Co. v. Commissioner
Docket Nos. 2344-64, 4951-64, 3987-65, 3988-65.
United States Tax Court
T.C. Memo 1968-229; 1968 Tax Ct. Memo LEXIS 72; 27 T.C.M. (CCH) 1114; T.C.M. (RIA) 68229;
October 3, 1968. Filed
Commercial Finance Company, a Colorado corporation, was dissolved in 1962, and all of its assets were distributed to its shareholders. Included in corporate assets were substantial debts due from the Estate of Gertrude Cullen, Deceased, the majority stockholder, some of which were secured by deeds of trust on business…
2Cases cited18 opinions
- Erie Railroad v. TompkinsSupreme Court of the United States · 1938
- Commissioner v. SternSupreme Court of the United States · 1958
- Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
- Mitton v. Granite State Fire Ins. Co. Granite State Fire Ins. Co. v. MittonCourt of Appeals for the Tenth Circuit · 1952
- Aurore B. Benoit, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
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