Schrott v. Commissioner
United States Tax Court
V abandoned a home security system which it paid to have installed in Ps' residence. Ps conceded that the abandonment of such system constituted a distribution of property with respect to V's stock taxable in the manner prescribed by section 301. Held: The amount of the distribution received by Ps equaled $ 8,250, the fair market value of the home security system on the date of distribution. UVB discharged a portion of Ps' indebtedness at a time when Ps were not insolvent.
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V abandoned a home security system which it paid to have installed in Ps' residence. Ps conceded that the abandonment of such system constituted a distribution of property with respect to V's stock taxable in the manner prescribed by section 301. Held: The amount of the distribution received by Ps equaled $ 8,250, the fair market value of the home security system on the date of distribution. UVB discharged a portion of Ps' indebtedness at a time when Ps were not insolvent. Held: Ps realized income from the discharge of indebtedness. Held further: Ps are not entitled to exclude or offset such…
1Opinion of the Court
JOHN D. SCHROTT AND ESTATE OF WINONA W. SCHROTT, DECEASED, JOHN D. SCHROTT, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Schrott v. Commissioner
Docket No. 42603-86
United States Tax Court
T.C. Memo 1989-346; 1989 Tax Ct. Memo LEXIS 345; 57 T.C.M. (CCH) 981; T.C.M. (RIA) 89346;
July 19, 1989
V abandoned a home security system which it paid to have installed in Ps' residence. Ps conceded that the abandonment of such system constituted a distribution of property with respect to V's stock taxable in the manner prescribed by section 301. Held: The amount of the distribution…
2Cases cited58 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
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3Cited by1 opinion
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