Frank Sawyer Trust of May 1992 v. Comm'r
United States Tax Court
P owned the stock of four corporations: TT, CT, St. Botolph, and Sixty-Five Bedford. The four corporations held assets with high fair market values and low adjusted bases. During 2000 and 2001 the corporations sold their assets, leaving the corporations with large cash reserves and facing large contingent tax liabilities.
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P owned the stock of four corporations: TT, CT, St. Botolph, and Sixty-Five Bedford. The four corporations held assets with high fair market values and low adjusted bases. During 2000 and 2001 the corporations sold their assets, leaving the corporations with large cash reserves and facing large contingent tax liabilities. Shortly after the respective asset sales, P sold its stock in the corporations to F. F, after purchasing the stock, transferred assets with inflated bases to the corporations. The corporations then sold these assets, generating losses. The losses were used to offset the…
1Opinion of the Court
FRANK SAWYER TRUST OF MAY 1992, TRANSFEREE, CAROL S. PARKS, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Frank Sawyer Trust of May 1992 v. Comm'r
No. 5526-07
United States Tax Court
133 T.C. 60; 2009 U.S. Tax Ct. LEXIS 20; 133 T.C. No. 3;
August 24, 2009., Filed
P owned the stock of four corporations: TT, CT, St. Botolph, and Sixty-Five Bedford. The four corporations held assets with high fair market values and low adjusted bases. During 2000 and 2001 the corporations sold their assets, leaving the corporations with large cash reserves and facing large contingent tax…
2Cases cited36 opinions
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- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
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- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
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