Helen M. Webb v. Commissioner of Internal Revenue

Fifth Circuit

Helen M. Webb v. Commissioner of Internal Revenue

572 F.2d 135, 41 A.F.T.R.2d (RIA) 1264, 1978 U.S. App. LEXIS 11487

Court of Appeals for the Fifth Circuit·Decided April 26, 1978·No. 77-1896·Published·Cited by 2 cases

Opinion

PER CURIAM:

The facts from which this controversy arose are quite complex. The primary question presented for review can be stated quite simply. That question is whether the purchase of the stock of a parent corporation by its subsidiary and the subsequent dissolution of the parent corporation gives rise to taxable dividend income of the parent corporation. The Commissioner asserts tax liability and asserts transferee liability against the appellees. The Tax Court resolved this question and the collateral issues against the Commissioner. Helen M. Webb, et al., 67 T.C. 293 (1976).

The Court of Appeals for the Seventh Circuit has recently decided the issue present here and approved the principle announced by the Tax Court in this case. Broadview Lumber Co., Inc. v. United States, 561 F.2d 698 (7th Cir. 1977). It is the opinion of this Court that the decision of the Tax Court should be and it is hereby AFFIRMED.

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PER CURIAM:

The facts from which this controversy arose are quite complex. The primary question presented for review can be stated quite simply. That question is whether the purchase of the stock of a parent corporation by its subsidiary and the subsequent dissolution of the parent corporation gives rise to taxable dividend income of the parent corporation. The Commissioner asserts tax liability and asserts transferee liability against the appellees. The Tax Court resolved this question and the collateral issues against the Commissioner. Helen M. Webb, et al., 67 T.C. 293 (1976).

The Court of Appeals for the Seventh Circuit has recently decided the issue present here and approved the principle announced by the Tax Court in this case. Broadview Lumber Co., Inc. v. United States, 561 F.2d 698 (7th Cir. 1977). It is the opinion of this Court that the decision of the Tax Court should be and it is hereby AFFIRMED.

Helen M. Webb v. Commissioner of Internal Revenue, 572 F.2d 135, 41 A.F.T.R.2d (RIA) 1264, 1978 U.S. App. LEXIS 11487 (5th Cir. 1978).

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Opinion

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