Legal Opinion

Haserot v. Commissioner

United States Tax Court

Decided September 30, 1966No. Docket No. 93774Published

Petitioner controlled corporations H, N, and G. Petitioner transferred to H all of his N and G stock and received a cash credit of $ 64,850 plus stock of H worth $ 48,640. Held on remand, the distribution of $ 64,850 was essentially equivalent to a dividend.

1Opinion of the Court

Henry McK. Haserot and Bonnie C. Haserot, Petitioners, v. Commissioner of Internal Revenue, Respondent

Haserot v. Commissioner

Docket No. 93774

United States Tax Court

46 T.C. 864; 1966 U.S. Tax Ct. LEXIS 37;

September 30, 1966, Filed

Decision will be entered that there is a deficiency of $ 90 in petitioners' income tax for the taxable year 1958.

Petitioner controlled corporations H, N, and G. Petitioner transferred to H all of his N and G stock and received a cash credit of $ 64,850 plus stock of H worth $ 48,640. Held on remand, the distribution of $ 64,850 was essentially equivalent to a dividend.

2Cases cited37 opinions

  1. Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Helvering v. HallockSupreme Court of the United States · 1940
  4. Bazley v. CommissionerSupreme Court of the United States · 1947
  5. Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942

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