Moffatt v. Commissioner
United States Tax Court
Held, distributions to shareholders were incident to a plan of reorganization, secs. 368(a)(1)(D) and 354(b)(1)(A), I.R.C. 1954, taxable as dividends to the extent provided in section 356(a) (2), rather than as capital gains pursuant to sections 331 and 346 dealing with corporate liquidations.
1Opinion of the Court
John G. Moffatt, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Moffatt v. Commissioner
Docket Nos. 1086-62, 1087-62, 1088-62, 1089-62, 1090-62, 1091-62, 1092-62
United States Tax Court
42 T.C. 558; 1964 U.S. Tax Ct. LEXIS 89;
June 16, 1964, Filed
Decisions will be entered under Rule 50.
Held, distributions to shareholders were incident to a plan of reorganization, secs. 368(a)(1)(D) and 354(b)(1)(A), I.R.C. 1954, taxable as dividends to the extent provided in section 356(a) (2), rather than as capital gains pursuant to sections 331 and 346 dealing with corporate liquidations.
2Cases cited34 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Heller v. CommissionerUnited States Tax Court · 1943
- Survaunt v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1947
- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
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