Legal Opinion

Field v. Commissioner

United States Tax Court

Decided April 24, 1959No. Docket Nos. 59565, 59566, 59567, 59568, 59569, 59570, 61244Published

A Michigan corporation was dissolved on April 27, 1951. Under Michigan law its corporate existence continued for 3 years, or longer, for the purpose of settling its affairs and concluding a proceeding commenced by it prior to dissolution or within the 3-year winding-up period. Immediately after dissolution, all of the corporation's assets were distributed to its stockholders.

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A Michigan corporation was dissolved on April 27, 1951. Under Michigan law its corporate existence continued for 3 years, or longer, for the purpose of settling its affairs and concluding a proceeding commenced by it prior to dissolution or within the 3-year winding-up period. Immediately after dissolution, all of the corporation's assets were distributed to its stockholders. At the time of dissolution, the corporation's liability for Federal taxes was in dispute and unsettled. The corporation, through its officers and liquidating directors, respectively, executed successive waivers in…

1Opinion of the Court

Ann C. Field, Transferee, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Field v. Commissioner

Docket Nos. 59565, 59566, 59567, 59568, 59569, 59570, 61244

United States Tax Court

32 T.C. 187; 1959 U.S. Tax Ct. LEXIS 186;

April 24, 1959, Filed

Decisions will be entered under Rule 50.

A Michigan corporation was dissolved on April 27, 1951. Under Michigan law its corporate existence continued for 3 years, or longer, for the purpose of settling its affairs and concluding a proceeding commenced by it prior to dissolution or within the 3-year winding-up period. Immediately after…

2Cases cited30 opinions

  1. Chicago Title & Trust Co. v. Forty-One Thirty-Six Wilcox Bldg. Corp.Supreme Court of the United States · 1937
  2. Oklahoma Natural Gas Co. v. OklahomaSupreme Court of the United States · 1927
  3. Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
  4. Stott v. Stott Realty Co.Michigan Supreme Court · 1939
  5. Benoit v. CommissionerUnited States Tax Court · 1955

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