Lester v. Commissioner
United States Tax Court
Petitioner and members of her family owned all the stock of General Auto Supply Co., which has been in the automotive parts and equipment business for a number of years both as a warehouse distributor and as a jobber.
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Petitioner and members of her family owned all the stock of General Auto Supply Co., which has been in the automotive parts and equipment business for a number of years both as a warehouse distributor and as a jobber. In 1957 General Auto caused a new corporation, Automotive Warehouse Co., to be formed and, under a written plan of reorganization adopted by both corporations, transferred the warehouse distribution business to Warehouse in exchange for all the stock of Warehouse which was issued directly to the stockholders of General Auto pro rata to their stockholdings in General Auto.…
1Opinion of the Court
Düennen, Judge:
Respondent determined a deficiency in petitioners’ income tax for the calendar year 1958 in the amount of $25,475.16.
The only issue is whether petitioner Anne Lee Lester (who will hereafter be referred to as petitioner) realized taxable income in the amount of $50,000 by reason of her receipt in 1958 of 500 shares of stock of Automotive Warehouse Co., Inc. (hereafter called Warehouse), in a reorganization of General Auto Supply Co. (hereafter called General Auto).
findings oe fact
Some of the facts have been stipulated and are found accordingly.
Petitioners are husband and wife…
2Cases cited9 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Burnet v. HarmelSupreme Court of the United States · 1932
- United States v. KalesSupreme Court of the United States · 1941
- Commissioner v. WheelerSupreme Court of the United States · 1945
- Coady v. CommissionerUnited States Tax Court · 1960
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Wilson v. CommissionerUnited States Tax Court · 1964
- Burke v. CommissionerUnited States Tax Court · 1964
- W. E. Gabriel Fabrication Co. v. CommissionerUnited States Tax Court · 1964
- Olson v. CommissionerUnited States Tax Court · 1967
- Estate of Lockwood v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1965
12 more not listed; retrieve them via the Exa API.