Adams v. Commissioner
United States Tax Court
At an informal meeting of the shareholders of Chippewa Springs Corporation on October 10, 1957, documents were executed with respect to a proposed sale of the corporate assets.
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At an informal meeting of the shareholders of Chippewa Springs Corporation on October 10, 1957, documents were executed with respect to a proposed sale of the corporate assets. The first, a memorandum, states that petitioner has offered $ 200,000 for the corporate assets, that the offer is conditional on the termination of the Chippewa trust which holds a majority of the corporate stock and in which petitioner has a 30-percent interest, that petitioner plans to finance part of the purchase price from his share of the trust, that upon petitioner's payment of the purchase price the corporate…
1Opinion of the Court
OPINION.
Scott, Judge:
Respondent determined that petitioner was liable as transferee of Chippewa Springs Corporation for a deficiency in the income tax of that corporation for the taxable year January 1 to October 21,1957, in the amount of $6,642.28, plus interest, as provided by law. Petitioner admits liability as transferee for Chippewa Springs Corporation leaving for decision the issue whether a loss of $21,716.34 sustained by that corporation on the sale of property should be recognized under the provisions of section 337(a) of the Internal Revenue Code of 1954.
All of the facts have been…
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