International Investment Corp. v. Commissioner of Internal Revenue

Third Circuit

International Investment Corp. v. Commissioner of Internal Revenue

175 F.2d 772, 38 A.F.T.R. (P-H) 124, 1949 U.S. App. LEXIS 3348

Court of Appeals for the Third Circuit·Decided June 20, 1949·No. 9931·Published·Cited by 1 cases

Opinion

PER CURIAM.

This is a petition to review a decision of the Tax Court that a loss claimed by the petitioner upon the complete liquidation of Portage Water Company, a wholly owned subsidiary, was not recognizable for income tax purposes under Section 112(b) (6) of the Internal Revenue Code, 26 U.S.C.A. § 112(b) (6). The property received by the petitioner upon the liquidation of its subsidiary consisted wholly of cash. Upon the authority of Tri-Lakes S. S. Co. v. Commissioner of Internal Revenue, 6 Cir. 1945, 146 F.2d 970, and for the reasons stated by the Tax Court in its opinion in the present case filed by Judge Kern, 11 T.C. 678, the decision of the Tax Court will be affirmed.

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PER CURIAM.

This is a petition to review a decision of the Tax Court that a loss claimed by the petitioner upon the complete liquidation of Portage Water Company, a wholly owned subsidiary, was not recognizable for income tax purposes under Section 112(b) (6) of the Internal Revenue Code, 26 U.S.C.A. § 112(b) (6). The property received by the petitioner upon the liquidation of its subsidiary consisted wholly of cash. Upon the authority of Tri-Lakes S. S. Co. v. Commissioner of Internal Revenue, 6 Cir. 1945, 146 F.2d 970, and for the reasons stated by the Tax Court in its opinion in the present case filed by Judge Kern, 11 T.C. 678, the decision of the Tax Court will be affirmed.

International Investment Corp. v. Commissioner of Internal Revenue, 175 F.2d 772, 38 A.F.T.R. (P-H) 124, 1949 U.S. App. LEXIS 3348 (3d Cir. 1949).

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Opinion

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