Northwestern Terra Cotta Corporation v. Commissioner of Internal Revenue

KILEY, Circuit Judge.

This is a petition to review a decision of the Tax Court which determined income tax deficiencies adversely to Taxpayer’s claim.

Taxpayer, an Illinois corporation, was organized by receivers for the Northwestern Terra Cotta Company, called “Company” here, under the direction of the District Court for the Northern District of Illinois in a creditor’s bill proceeding. Pursuant to “The Plan for Liquidating * * * ” the Company, the receivers exchanged for all of Taxpayer’s stock the Company’s cash, personalty and intangibles. The receivers also, under the Plan, leased to…