Legal Opinion
Glenn C. Bailey, Lillian S. Bailey, and Inez N. Bailey v. United States
Court of Appeals for the Ninth Circuit
Decided March 25, 1966No. 19874PublishedCited by 4 opinions
1Opinion of the Court
BROWNING, Circuit Judge:
The question presented is whether taxpayers who intended to achieve a non-taxablc corporate liquidation under section 112(b) (7) of the Internal Revenue Code of 1939 entertained the “view” which would have rendered the corporation “collapsible” within the meaning of 1939 Code section 117(m). The district court held that they did, and we affirm.
The taxpayers were engaged in subdividing real property and building and selling homes. They purchased an unimproved parcel in Santa Ana, California, in November 1951, and by July 31, 1952, had constructed one hundred and twenty…
2Cases cited9 opinions
- The Grand Lodge of the International Association of MacHinists Etc. v. John J. King, Earl N. AndersonCourt of Appeals for the Ninth Circuit · 1964
- Braunstein v. CommissionerSupreme Court of the United States · 1963
- Temkin v. CommissionerUnited States Tax Court · 1961
- Commissioner of Internal Revenue v. Ralph J. Solow and Celia O. SolowCourt of Appeals for the Second Circuit · 1964
- Commissioner of Internal Revenue v. Sylvester J. Lowery and Rosemary P. LoweryCourt of Appeals for the Third Circuit · 1964
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3Cited by4 opinions
- Pension Benefit Guaranty Corp. v. Center City Motors, Inc.District Court, S.D. California · 1984
- Kennecott Copper Corp. v. TrainCourt of Appeals for the Ninth Circuit · 1975
- Joseph Lupowitz Sons, Inc. v. CommissionerUnited States Tax Court · 1972
- Brock v. Local 1130, Laborers' International UnionDistrict Court, E.D. California · 1987