Auto Finance Company v. Commissioner of Internal Revenue

Fourth Circuit

Auto Finance Company v. Commissioner of Internal Revenue

229 F.2d 318

Court of Appeals for the Fourth Circuit·Decided January 13, 1956·No. 7123_1·Published·Cited by 1 cases

Opinion

PER CURIAM.

This is an appeal from a decision of the Tax Court holding that the intercorporate transactions there under review, by which the taxpayer corporation disposed of its majority interest in the stock of two corporations to the minority stockholders, resulted in capital gain taxable as such and were not taxable dividends for which taxpayer would have been entitled to credit allowance under 26 U.S.C. § 26(b). The facts are fully and correctly set forth in the opinion of the Tax Court and need not be repeated here. See 24 T.C. -. We think that the decision of the Tax Court was correct for reasons adequately stated in its opinion and that nothing need be added thereto.

Affirmed,

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PER CURIAM.

This is an appeal from a decision of the Tax Court holding that the intercorporate transactions there under review, by which the taxpayer corporation disposed of its majority interest in the stock of two corporations to the minority stockholders, resulted in capital gain taxable as such and were not taxable dividends for which taxpayer would have been entitled to credit allowance under 26 U.S.C. § 26(b). The facts are fully and correctly set forth in the opinion of the Tax Court and need not be repeated here. See 24 T.C. -. We think that the decision of the Tax Court was correct for reasons adequately stated in its opinion and that nothing need be added thereto.

Affirmed,

Auto Finance Company v. Commissioner of Internal Revenue, 229 F.2d 318 (4th Cir. 1956).

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Opinion

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