Abegg v. Commissioner
United States Tax Court
Abegg, a nonresident alien in 1957, liquidated Hevaloid, a wholly owned Delaware corporation, which was a personal holding company, and exchanged the property and cash he then received for all the stock of Suvretta, a Panama corporation, also a personal holding company.
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Abegg, a nonresident alien in 1957, liquidated Hevaloid, a wholly owned Delaware corporation, which was a personal holding company, and exchanged the property and cash he then received for all the stock of Suvretta, a Panama corporation, also a personal holding company. The name Suvretta was changed to Cresta on or about Mar. 5, 1958. In February 1958 he contributed additional securities to the capital of Suvretta having fair market values some in excess of his basis and some below his basis. No ruling under sec. 367 was requested. In 1958, 1959, and 1960 Cresta unsuccessfully sought…
1Opinion of the Court
Werner Abegg, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Abegg v. Commissioner
Docket Nos. 1570-62, 1571-62, 1572-62
United States Tax Court
50 T.C. 145; 1968 U.S. Tax Ct. LEXIS 139;
April 24, 1968, Filed
Decisions will be entered under Rule 50.
Abegg, a nonresident alien in 1957, liquidated Hevaloid, a wholly owned Delaware corporation, which was a personal holding company, and exchanged the property and cash he then received for all the stock of Suvretta, a Panama corporation, also a personal holding company. The name Suvretta was changed to Cresta on or about Mar. 5,…
2Cases cited37 opinions
- Dixon v. United StatesSupreme Court of the United States · 1965
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Frank v. CommissionerUnited States Tax Court · 1953
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