Mid-Southern Foundation v. Commissioner
United States Tax Court
Madison Avenue Corporation, during and prior to the taxable periods involved, was engaged in managing and leasing office space in the Sterick Building, its principal asset, located in Memphis, Tennessee. From approximately August 1946 to November 1949, inclusive, it also owned and operated a farm as a branch business.
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Madison Avenue Corporation, during and prior to the taxable periods involved, was engaged in managing and leasing office space in the Sterick Building, its principal asset, located in Memphis, Tennessee. From approximately August 1946 to November 1949, inclusive, it also owned and operated a farm as a branch business. On June 10, 1952, petitioner acquired all outstanding stock of Madison, all the assets of Madison were transferred to petitioner, and petitioner assumed all the liabilities of said corporation. The corporate charter of Madison was surrendered on June 10, 1952. Respondent…
1Opinion of the Court
Beuoe, Judge:
Respondent determined the liability of petitioner as transferee for the deficiencies in the income tax of Madison Avenue Corporation, transferor, in the following amounts:
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In the petition filed herein, petitioner claimed that the transferor overpaid its taxes in 1950 and 1951 in the amounts of $7,342.63 and $9,881.81, respectively.
Petitioner concedes its liability as transferee and has abandoned its claim that the statute of limitations barred the imposition of transferee liability. The issues presented concern the liability of the transferor and are as follows:(1)…
2Cases cited4 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Bullock v. CommissionerUnited States Tax Court · 1956
- McDaniel v. CommissionerUnited States Tax Court · 1955
- Thomas Paper Stock Co. v. CommissionerUnited States Tax Court · 1954
3Cited by7 opinions
- Wright Contracting Co. v. CommissionerUnited States Tax Court · 1961
- Mid-Southern Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
- Kentucky Farm & Cattle Co. v. CommissionerUnited States Tax Court · 1958
- Kentucky Farm & Cattle Co. v. CommissionerUnited States Tax Court · 1958
- Mid-Southern Foundation v. CommissionerUnited States Tax Court · 1957
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