Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Construction Co., a corporation engaged for more than five years prior to November 15, 1954, in the conduct of a construction business. On that day the parent, Christopher Company, organized a subsidiary, E. P. Coady & Co., to which it transferred approximately one half of its contracts, equipment, and cash. In exchange, the parent company received all the stock of the subsidiary. Immediately thereafter, the parent distributed to petitioner, one of the two equal shareholders of the parent company, all the stock of the subsidiary in exchange for petitioner\u27s stock in the parent. Although the fair market value of the shares received exceeded t...
Defendant parent corporation received from its subsidiary 3,556,992 dollars in tax benefits which ha...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Co...
Petitioners had formed a corporation for the purpose of building and operating a housing project. Af...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
In 1948 petitioner and several other taxpayers, who had previously been active in constructing homes...
Petitioners, from 1937 to 1940, received distributions from the liquidation of a corporation of whic...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
The taxpayer purchased A Company stock from X for $100,000 and later sold it for $7,500, deducting t...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the ope...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
Defendant parent corporation received from its subsidiary 3,556,992 dollars in tax benefits which ha...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Co...
Petitioners had formed a corporation for the purpose of building and operating a housing project. Af...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
In 1948 petitioner and several other taxpayers, who had previously been active in constructing homes...
Petitioners, from 1937 to 1940, received distributions from the liquidation of a corporation of whic...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
The taxpayer purchased A Company stock from X for $100,000 and later sold it for $7,500, deducting t...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the ope...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
Defendant parent corporation received from its subsidiary 3,556,992 dollars in tax benefits which ha...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...