Maguire v. Commissioner
United States Tax Court
In 1944, Mokan offered to redeem the stock of any stockholder in exchange for a proportionate share of its assets. Such offer remained in effect at least through 1966, and in 1960, the petitioners received distributions of the earnings and profits of Mokan, not in redemption of their stock.
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In 1944, Mokan offered to redeem the stock of any stockholder in exchange for a proportionate share of its assets. Such offer remained in effect at least through 1966, and in 1960, the petitioners received distributions of the earnings and profits of Mokan, not in redemption of their stock. The Tax Court held that Mokan was not in the process of complete liquidation in 1945 and that its distributions out of earnings and profits during such year were not liquidating distributions, but that decision was reversed by the Seventh Circuit. Held, collateral estoppel does not apply in the…
1Opinion of the Court
Estate of William G. Maguire, Deceased, Marian L. Maguire, Robert M. Morgenthau and United States Trust Company of New York, Executors, and Marian L. Maguire, Petitioners v. Commissioner of Internal Revenue, Respondent
Maguire v. Commissioner
Docket No. 3359-64
United States Tax Court
50 T.C. 130; 1968 U.S. Tax Ct. LEXIS 138;
April 24, 1968, Filed
Decision will be entered under Rule 50.
In 1944, Mokan offered to redeem the stock of any stockholder in exchange for a proportionate share of its assets. Such offer remained in effect at least through 1966, and in 1960, the petitioners received…
2Cases cited18 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- Burford-Toothaker Tractor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- R. D. Merrill Co. v. CommissionerUnited States Tax Court · 1945
- Stoddard v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
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