Virginia Ice & Freezing Corp. v. Commissioner
United States Tax Court
Petitioner sold 2 pieces of property at a loss on October 1 and 4, 1954, respectively. When the directors met on October 1 to approve the first sale, they caused to be entered in petitioner's minute book a notice to themselves that a meeting would be held on Ocober 11, 1954. On the latter date a majority of the directors met and adopted a resolution recommending that the petitioner be dissolved and called a meeting of the stockholders for October 22, 1954, to act on the…
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Petitioner sold 2 pieces of property at a loss on October 1 and 4, 1954, respectively. When the directors met on October 1 to approve the first sale, they caused to be entered in petitioner's minute book a notice to themselves that a meeting would be held on Ocober 11, 1954. On the latter date a majority of the directors met and adopted a resolution recommending that the petitioner be dissolved and called a meeting of the stockholders for October 22, 1954, to act on the matter. At the meeting held on October 22, 1954, the stockholders approved the recommendation and adopted a resolution that…
1Opinion of the Court
Akundell, Judge:
The respondent determined a deficiency in income tax for the taxable year ended December 31, 1954, in the amount of $10,017.76.
The issue involved is whether the respondent erred in disallowing a loss of $19,200.44 on the sales of certain properties claimed by petitioner on its corporation income tax return for the calendar year 1954 on the ground that in accordance with section 337 (a) of the Internal Revenue Code of 1954, such sales were made within the 12-month period beginning on the date of the adoption of a plan of complete liquidation and, under section 337 (a), no gain…
2Cases cited2 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
3Cited by14 opinions
- Mountain Water Co. v. CommissionerUnited States Tax Court · 1960
- City Bank of Washington v. CommissionerUnited States Tax Court · 1962
- Adams v. CommissionerUnited States Tax Court · 1962
- Howell v. CommissionerUnited States Tax Court · 1963
- West Street-Erie Boulevard Corporation v. United StatesCourt of Appeals for the Second Circuit · 1969
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