Fawn Fashions, Inc. v. Commissioner
United States Tax Court
Petitioner, a sales corporation, incurred substantial operating losses in the first year and a half of its operations and in December 1955 ceased operations. In April 1956, after petitioner had been placed in receivership, its assets were sold.
Read the full summary
Petitioner, a sales corporation, incurred substantial operating losses in the first year and a half of its operations and in December 1955 ceased operations. In April 1956, after petitioner had been placed in receivership, its assets were sold. More than a year later, petitioner's franchise, corporate name, and other rights or privileges contained in its charter of incorporation were purchased by a manufacturing and sales corporation, which put petitioner through Federal bankruptcy proceedings and then, early in 1958, transferred its sales activities to petitioner. Held, petitioner's…
1Opinion of the Court
OPINION
Section 269 provides that if “any person or persons acquire, or acquired on or after October 8, 1940, directly or indirectly, control of a corporation * * * and the principal purpose for which such acquisition was made is evasion or avoidance of Federal income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then such deduction, credit, or other allowance shall not be allowed.” Section 269(c)2 provides that where the corporation described in section 269(a) is acquired for a purchase price which is…
2Cases cited2 opinions
- R. P. Collins & Co., Inc. v. United StatesCourt of Appeals for the First Circuit · 1962
- Zanesville Inv. Co. v. CommissionerUnited States Tax Court · 1962
3Cited by23 opinions
- United States v. Fenix and Scisson, Inc., a CorporationCourt of Appeals for the Tenth Circuit · 1966
- H. F. Ramsey Co. v. CommissionerUnited States Tax Court · 1965
- Beckett v. CommissionerUnited States Tax Court · 1963
- Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
- Euclid-Tennessee, Inc. v. CommissionerUnited States Tax Court · 1964
18 more not listed; retrieve them via the Exa API.