Telephone Answering Service Co. v. Commissioner
United States Tax Court
TASCO owned 100 percent of the stock of both Houston and North American in addition to operating a telephone-answering service directly and providing managerial services to those two subsidiaries, which themselves operated telephone-answering services.
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TASCO owned 100 percent of the stock of both Houston and North American in addition to operating a telephone-answering service directly and providing managerial services to those two subsidiaries, which themselves operated telephone-answering services. After having been approached concerning the stock of Houston, TASCO on Mar. 18, 1966, created New TASCO as a wholly owned subsidiary and on May 13, 1966, adopted a plan of liquidation and approved the sale of the Houston stock. The sale was closed on Oct. 31, 1966. On Mar. 31, 1967, TASCO transferred all its assets excluding its North American…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined deficiencies of $8,527.55 and $72,329.02 in the Federal income taxes of petitioner, which filed consolidated returns, for the taxable years ended November 30,1965, and November 30,1966, respectively. Concessions having been made, the sole issue for determination is whether the gain realized by petitioner on the sale of all the stock of one of its subsidiaries to a third party is to be recognized. The resolution of this issue depends upon whether the factual pattern involved herein meets the requirements of section 337.1
All of the facts have been…
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