Dunn Trust v. Commissioner
United States Tax Court
In 1982, AT&T acquired additional stock of Pacific, a subsidiary corporation, in a taxable transaction. Pursuant to a plan of reorganization and divestiture, AT&T transferred all of its Pacific stock, along with other assets, to PacTel Group, a holding company, in a nontaxable exchange for PacTel Group stock, by virtue of which AT&T acquired control of PacTel Group within the meaning of sec. 368(c), I.R.C., 1954. On Jan. 1, 1984, AT&T distributed its PacTel Group stock to…
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In 1982, AT&T acquired additional stock of Pacific, a subsidiary corporation, in a taxable transaction. Pursuant to a plan of reorganization and divestiture, AT&T transferred all of its Pacific stock, along with other assets, to PacTel Group, a holding company, in a nontaxable exchange for PacTel Group stock, by virtue of which AT&T acquired control of PacTel Group within the meaning of sec. 368(c), I.R.C., 1954. On Jan. 1, 1984, AT&T distributed its PacTel Group stock to its shareholders. Held, no portion of the PacTel Group stock distributed to AT&T's shareholders constitutes "other…
1Opinion of the Court
OPINION
TANNENWALD, Judge:
Respondent determined a deficiency of $29.64 in petitioner’s Federal income taxes for the taxable year ended May 31, 1984. The issue for decision is whether a portion of the stock distributed to petitioner pursuant to a reorganization and divestiture plan constituted “other property” under section 355(a)(3)(B).1
This case was submitted fully stipulated under Rule 122. This reference incorporates herein the stipulation of facts and attached exhibits. We will set forth only those highly detailed stipulated facts (or a summary thereof) as are necessary to an understanding…
2Cases cited18 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- United States v. American Telephone & Telegraph Co.District Court, District of Columbia · 1983
- Helvering v. HammelSupreme Court of the United States · 1941
- Helvering v. PowersSupreme Court of the United States · 1934
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
13 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Huntsman v. CommissionerUnited States Tax Court · 1988
- Guilzon v. CommissionerUnited States Tax Court · 1991
- CSX Corp. v. CommissionerUnited States Tax Court · 1987
- Intel Corp. & Consol. Subsidiaries v. CommissionerUnited States Tax Court · 1998
- Bhada v. CommissionerUnited States Tax Court · 1987
10 more not listed; retrieve them via the Exa API.