Allied Utilities Corp. v. Commissioner
United States Tax Court
Petitioner, a wholly owned subsidiary of Allied Telephone Co. (Allied), on May 5, 1965, acquired all the stock of Crossett Telephone Co. (Crossett), a corporation formed that day by a corporation other than petitioner or Allied. On May 5, after petitioner acquired Crossett's stock, the stockholders and directors of Crossett passed a resolution to liquidate and dissolve Crossett.
Read the full summary
Petitioner, a wholly owned subsidiary of Allied Telephone Co. (Allied), on May 5, 1965, acquired all the stock of Crossett Telephone Co. (Crossett), a corporation formed that day by a corporation other than petitioner or Allied. On May 5, after petitioner acquired Crossett's stock, the stockholders and directors of Crossett passed a resolution to liquidate and dissolve Crossett. A certificate of dissolution of Crossett attaching a copy of this resolution was filed with the secretary of state of Arkansas on May 6, 1965. Crossett filed a corporate income tax return for its taxable year…
1Opinion of the Court
Scott, Judge:
Respondent determined that petitioner was liable, as transferee, for a deficiency in Federal income tax in the amount of $4,333 of Crossett Telephone Co. for its taxable year ending May 6,1965.
The only issue for decision is whether Crossett Telephone Co. in computing its surtax under section 11,1.R.C. 1954,1 is entitled to a surtax exemption in the amount of $25,000 or in the amount of $8,334.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Allied Utilities Corp. (petitioner) is an Arkansas corporation which had its principal office in Little Rock,…
2Cases cited5 opinions
- Weir Long Leaf Lumber Co. v. CommissionerUnited States Tax Court · 1947
- Wier Long Leaf Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
- Weir v. CommissionerUnited States Tax Court · 1948
- Hooper v. CommissionerUnited States Board of Tax Appeals · 1932
- Tow v. CommissionerUnited States Tax Court · 1961
3Cited by3 opinions
- Red Carpet Car Wash, Inc. v. CommissionerUnited States Tax Court · 1980
- Allied Utilities Corp. v. CommissionerUnited States Tax Court · 1975
- Red Carpet Car Wash, Inc. v. CommissionerUnited States Tax Court · 1980