Mills Estate, Inc. v. Commissioner
United States Tax Court
Deduction for legal expenses in connection with amendment of a corporation's charter, retiring its outstanding capital stock, issuance of new stock in reduced amount, and distribution of assets in partial liquidation, allowed in part and disallowed in part.
1Opinion of the Court
OPINION.
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The essential facts are not in dispute. Petitioner is a closely held corporation organized primarily for the two purposes of holding stock in a California corporation, and of acquiring certain improved real estate in New York City. In January 1917, shortly after its formation, it acquired both the stock and the real estate in question. Years later, in March 1941, the real estate was sold for $"3,625,000.
After considering what to do with the sales proceeds, and after giving thought to the possibility of completely liquidating petitioner, it was decided rather to file a…
2Cases cited9 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. WinmillSupreme Court of the United States · 1938
- Spreckels v. CommissionerSupreme Court of the United States · 1942
- Survaunt v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1947
- Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
4 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Gravois Planing Mill Company, Charles A. And Florence Beckemeier v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Standard Linen Service, Inc. v. CommissionerUnited States Tax Court · 1959
- Cagle v. CommissionerCourt of Appeals for the Fifth Circuit · 1976
- Mid-State Products Co. v. CommissionerUnited States Tax Court · 1954
- National Starch & Chemical Corp. v. CommissionerUnited States Tax Court · 1989
21 more not listed; retrieve them via the Exa API.