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Income Tax- Corporations-Legal Expenses Incurred In Sale Of Assets Pursuant To A Section 337 Liquidation Are Deductible-United States V. Mountain States Mixed Feed Co., Michigan Law Review
Income Tax- Corporations-Legal Expenses Incurred In Sale Of Assets Pursuant To A Section 337 Liquidation Are Deductible-United States V. Mountain States Mixed Feed Co., Michigan Law Review
Michigan Law Review
In 1961, the stockholders of the Mountain States Mixed Feed Co. voted to liquidate the corporation in such a way as to comply with the requirements of section 337 of the Internal Revenue Code of 1954 (Code). That section provides that if a corporation adopts a plan of complete liquidation, and then within twelve months distributes all its assets, it will not recognize a gain or loss for income tax purposes from the sale or exchange of certain types of property. The corporation sold all of its assets and qualified for non-recognition treatment under section 337. It then claimed a …
Gift Taxes-Interest-Free Demand Loans Are Not Taxable Gifts-Johnson V. United States, Michigan Law Review
Gift Taxes-Interest-Free Demand Loans Are Not Taxable Gifts-Johnson V. United States, Michigan Law Review
Michigan Law Review
Over a period of several years, taxpayer transferred substantial amounts of money to his adult son as loans that were repayable on demand and did not bear interest. The Commissioner of Internal Revenue assessed and collected gift taxes on the theory that taxpayer had made gifts to his son of the use of the money loaned. The value of the gift was asserted to be 3½ per cent of the average unpaid balance as of the end of each of the taxable years involved. In a suit to recover the gift taxes paid, the Federal District Court for the Northern …
Estate Tax-The Failure Of I.R.C. Section 2039 To Reach Death Benefits Arising Out Of The Employment Relationship-Estate Of Fusz, Michigan Law Review
Estate Tax-The Failure Of I.R.C. Section 2039 To Reach Death Benefits Arising Out Of The Employment Relationship-Estate Of Fusz, Michigan Law Review
Michigan Law Review
Decedent's employment contract provided for a salary payable to him and monthly payments to his widow for life if he died during the term of the contract. No post-retirement benefits were payable to decedent under the contract or pursuant to any other agreement with the employer. After decedent's death during the term of the contract the payments to his widow commenced; their commuted value, however, was not included in the gross estate of decedent. The Commissioner of Internal Revenue, ruling that the payments to the widow constituted an annuity, the commuted value of which was includable in decendent's gross estate …