Idol v. Commissioner
United States Tax Court
1. Payments made by petitioner Speedway Transports, Inc., to petitioner Edgar S. Idol during 1956 and 1957 constitute dividend distributions. 2. The purported reacquisition of stock by Speedway in exchange for certain assets (an operating franchise and 15 pieces of equipment) during 1957 constituted a sale of assets. 3. Petitioner Edgar S. Idol's receipt of $ 40,000 on May 1, 1957, constituted a dividend distribution to him by Speedway.
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in petitioners’ income tax for the years and in the amounts as follows:
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The issues presented for our decision are the correctness of the respondent’s action in determining (1) that payments made by petitioner Speedway Transports, Inc., to petitioner Edgar S. Idol during 1958 and 1957 constitute dividend distributions; (2) that the disposition of certain assets by petitioner Speedway Transports, Inc., to Cassens Transport Company during 1957 resulted in the realization of capital gain; and (3) that petitioner Edgar S. Idol…
2Cases cited14 opinions
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Commissioner of Internal Revenue v. Ashland Oil & Refining Co.Court of Appeals for the Sixth Circuit · 1938
9 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
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- Dean v. CommissionerUnited States Tax Court · 1971
- Rapid Electric Co. v. CommissionerUnited States Tax Court · 1973
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