Massey's Auto Body Shop, Inc. v. Commissioner
United States Tax Court
Held, petitioner has established by the clear preponderance of the evidence that a major purpose of a corporate transfer of assets to it was not the securing of a surtax exemption within the meaning of sec. 1551(a), I.R.C. 1954. Respondent's disallowance of such exemption is disapproved.
1Opinion of the Court
MASSEY'S AUTO BODY SHOP, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Massey's Auto Body Shop, Inc. v. Commissioner
Docket No. 2860-76.
United States Tax Court
T.C. Memo 1978-414; 1978 Tax Ct. Memo LEXIS 99; 37 T.C.M. (CCH) 1723; T.C.M. (RIA) 78414;
October 16, 1978, Filed
Held, petitioner has established by the clear preponderance of the evidence that a major purpose of a corporate transfer of assets to it was not the securing of a surtax exemption within the meaning of sec. 1551(a), I.R.C. 1954. Respondent's disallowance of such exemption is disapproved.
Earl S. Wellschlager,…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bush Hog Mfg. Co. v. CommissionerUnited States Tax Court · 1964
- Truck Terminals, Inc., on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Ninth Circuit · 1963
- Sno-Frost, Inc. v. CommissionerUnited States Tax Court · 1959
- Hiawatha Home Builders, Inc. v. CommissionerUnited States Tax Court · 1961
2 more not listed; retrieve them via the Exa API.