Madison Square Garden Corp. v. Commissioner
United States Tax Court
Petitioner purchased a controlling interest in another corporation. That corporation then redeemed some of its stock so that petitioner owned approximately 79 percent of its stock. Petitioner then purchased sufficient stock of the other corporation to own over 80 percent.
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Petitioner purchased a controlling interest in another corporation. That corporation then redeemed some of its stock so that petitioner owned approximately 79 percent of its stock. Petitioner then purchased sufficient stock of the other corporation to own over 80 percent. After petitioner owned 80 percent of the stock of the other corporation, it liquidated (by merger) its subsidiary in a transaction which respondent concedes came within the provisions of sec. 332, I.R.C. 1954. Held: The basis of the assets received by petitioner on the liquidation is determined under sec. 334(b)(2). Amount…
1Opinion of the Court
OPINION
Soorr, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes for the taxable years and in the amounts as follows:
Amount Year ended Deo. SI
$84, 300. 00 1957 _
21, 222.37 1958 _
75, 914.43 1960 _
126, 526.93 1961_
Some of the issues raised by the pleadings have been disposed of by the parties, leaving for our decision:(1) Whether petitioner acquired 80 percent of the stock of Madison Square Garden Corp. by “purchase” within the meaning of section 334(b) (2), I.E.C. 1954,1 so as to entitle petitioner to use as the basis of the property acquired from Madison Square…
2Cases cited6 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- Boise Cascade Corporation v. United StatesDistrict Court, D. Idaho · 1968
- Bijou Park Properties, Inc. v. CommissionerUnited States Tax Court · 1966
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3Cited by14 opinions
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- George L. Riggs, Inc. v. CommissionerUnited States Tax Court · 1975
- Madison Square Garden Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1974
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