Keck v. Commissioner
United States Tax Court
In 1956 an executory contract was entered into by three corporations engaged in various aspects of the motor transportation business to sell all of their assets, provided, however, that the requisite approval of the Interstate Commerce Commission could be obtained, and provided further that the selling corporations could obtain a ruling from the Internal Revenue Service that the gain realized by the corporations from the transfer of assets would be exempt from Federal income…
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In 1956 an executory contract was entered into by three corporations engaged in various aspects of the motor transportation business to sell all of their assets, provided, however, that the requisite approval of the Interstate Commerce Commission could be obtained, and provided further that the selling corporations could obtain a ruling from the Internal Revenue Service that the gain realized by the corporations from the transfer of assets would be exempt from Federal income tax under sec. 337, I.R.C. 1954. Pursuant to the contract, Shaw and the other stockholders delivered their stock in the…
1Opinion of the Court
OPINION
Mulroney, Judge:
Respondent determined a deficiency in the income tax of George W. and Mary Ann Keck in docket No. 5326-65 in the amount of $65,919.76 for the year 1960. Respondent also asserted transferee liability in docket No. 5327-65 against Mary Ann Keck in the amount of $139,401.05, plus interest, as transferee of the assets of the Estate of Arthur D. Shaw. The issue in these consolidated cases is whether certain amounts received in 1960 by Mary Ann Keck and by the estate were taxable as income in respect of a decedent under the provisions of section 691 of the 1954 Code.1
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2Cases cited4 opinions
- Helvering v. Estate of EnrightSupreme Court of the United States · 1941
- Commissioner of Internal Revenue v. LindeCourt of Appeals for the Ninth Circuit · 1954
- Estate of Helen Davison, Deceased, First National Bank of Arizona v. United StatesCourt of Appeals for the First Circuit · 1961
- Trust Company of Georgia v. RossDistrict Court, N.D. Georgia · 1966
3Cited by16 opinions
- Rollert Residuary Trust v. CommissionerUnited States Tax Court · 1983
- Estate of Sidles v. CommissionerUnited States Tax Court · 1976
- Dorsey v. CommissionerUnited States Tax Court · 1968
- Estate of Peterson v. CommissionerUnited States Tax Court · 1980
- Estate of Bickmeyer v. CommissionerUnited States Tax Court · 1985
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