Morgan v. Commissioner
United States Tax Court
Petitioners' partnership paid $ 8,400 for equipment acquired by Junction Drilling Co. on February 23, 1961. Junction was formally incorporated on March 2, 1961. The directors of Junction adopted a "plan" for issuance of stock under section 1244, I.R.C. 1954, in the minutes of their meeting on April 3, 1961. The certificate of stock representing 8,400 shares of stock of Junction was issued to the partnership on May 29, 1961. Junction adopted a resolution to liquidate and…
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Petitioners' partnership paid $ 8,400 for equipment acquired by Junction Drilling Co. on February 23, 1961. Junction was formally incorporated on March 2, 1961. The directors of Junction adopted a "plan" for issuance of stock under section 1244, I.R.C. 1954, in the minutes of their meeting on April 3, 1961. The certificate of stock representing 8,400 shares of stock of Junction was issued to the partnership on May 29, 1961. Junction adopted a resolution to liquidate and dissolve on September 15, 1961, at which time it needed about $ 25,726 to pay all of its creditors, including two…
1Opinion of the Court
Dbennen, Judge:
In these consolidated proceedings respondent determined deficiencies in petitioners’ income tax for the taxable year 1961 as follows:
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By amendment to answer respondent has asserted claims for increased deficiencies in income tax against each of the joint petitioners, over and above those set forth above, for the taxable year 1961 as follows:
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The issues presented for our consideration are:(1) Whether all or any part of the amounts claimed on petitioners’ returns as a loss incurred by Petroleum Drilling Co., a partnership (totaling $29,503) should be…
2Cases cited6 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Dunn & McCarthy, Inc. v. CommissionerCourt of Appeals for the Second Circuit · 1943
- Don T. Allen and Don T. Allen as of the Estate of Helen M. Allen, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
- Marsh v. CommissionerUnited States Tax Court · 1949
- Thomas v. ThomasSupreme Court of Colorado · 1921
1 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Estate of Campbell v. CommissionerUnited States Tax Court · 1971
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Smyers v. CommissionerUnited States Tax Court · 1971
- Godart v. CommissionerUnited States Tax Court · 1969
- Perrett v. CommissionerUnited States Tax Court · 1980
69 more not listed; retrieve them via the Exa API.