Legal Opinion

Sheldon v. Commissioner

United States Tax Court

Decided March 19, 1946No. Docket Nos. 6203, 6204, 6205Published

1. A distribution by a corporation out of earnings and profits made as an integral part of a merger amounting to a tax-free reorganization and in order to equalize its assets with those of the other merging corporation, held to have had the effect of a taxable dividend within the meaning of Internal Revenue Code, section 112 (c) (2). 2. Contributions to a fire department benevolent association, held deductible as a charitable contribution under Internal Revenue Code, section…

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1. A distribution by a corporation out of earnings and profits made as an integral part of a merger amounting to a tax-free reorganization and in order to equalize its assets with those of the other merging corporation, held to have had the effect of a taxable dividend within the meaning of Internal Revenue Code, section 112 (c) (2). 2. Contributions to a fire department benevolent association, held deductible as a charitable contribution under Internal Revenue Code, section 23 (o).

1Opinion of the Court

Isabella M. Sheldon, Petitioner, v. Commissioner of Internal Revenue, Respondent. Julia S. Ludwig, Petitioner, v. Commissioner of Internal Revenue, Respondent. Ralph C. Sheldon, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent

Sheldon v. Commissioner

Docket Nos. 6203, 6204, 6205

United States Tax Court

6 T.C. 510; 1946 U.S. Tax Ct. LEXIS 259;

March 19, 1946, Promulgated

Decision will be entered under Rule 50.

1. A distribution by a corporation out of earnings and profits made as an integral part of a merger amounting to a tax-free reorganization and in order to equalize its assets…

2Cases cited6 opinions

  1. Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
  2. Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
  3. McKenna v. CommissionerUnited States Tax Court · 1945
  4. Munter v. CommissionerUnited States Tax Court · 1945
  5. Spirella Co. v. CommissionerUnited States Tax Court · 1945

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