Allen v. Commissioner
United States Tax Court
Petitioners, the owners of all the issued and outstanding shares of TCC, donated 77 percent of their shares to a charitable organization. Prior to the gift, TCC had adopted a plan of liquidation, and corporate resolutions had directed that all necessary action be taken to wind up the affairs of TCC and to distribute specified corporate assets to petitioners and to the contemplated charitable donee in complete liquidation so that no further authorization was required.
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Petitioners, the owners of all the issued and outstanding shares of TCC, donated 77 percent of their shares to a charitable organization. Prior to the gift, TCC had adopted a plan of liquidation, and corporate resolutions had directed that all necessary action be taken to wind up the affairs of TCC and to distribute specified corporate assets to petitioners and to the contemplated charitable donee in complete liquidation so that no further authorization was required. The assets were so distributed immediately following the transfer of the donated shares. Held, the transfers constituted an…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
1971 1972
Horace E. and Katherine M. Allen_ $108.22
Charles D. and Edna N. Cobau- 848.07
James G. and Jean M. Diller_ 1,521.00
Edward L. and Norma Doermann- 5,412.79
Harvey C. and Marjorie Gunderson_ 1,970.38 $6,402.00
Frederick B. and Jane Hawkins- 8,403.00
Robert C. and Anita Hawkins_ 6,906.00
Harland F. and Gratia Howe- 1,004.31
Ward S. and Elizabeth H. Jenkins_ 5,703.32
Thomas J. and Inez M. O’Grady- 570.00
Edward G. and Helen L.Seybold_ 4,727.03 915.76
John D. and Lucile A. Skow_ 881.00
Danie…
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. HorstSupreme Court of the United States · 1940
20 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Gordon v. CommissionerUnited States Tax Court · 1985
- Roberts v. CommissionerUnited States Tax Court · 1978
- Weaver v. CommissionerUnited States Tax Court · 1978
- Estate of Applestein v. CommissionerUnited States Tax Court · 1983
17 more not listed; retrieve them via the Exa API.