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T. V. D. CO. v. COMMISSIONER

Docket No. 58804.

27 T.C. 879 (1957)

THE T. V. D. Co. (FORMERLY THE DUBOIS CO.), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 28, 1957.

Attorney(s) appearing for the Case

Harry B. Sutter, Esq., Peter L. Wentz, Esq., William P. Sutter, Esq., and Edward Rothbart, Esq., for the petitioner.

Lyman G. Friedman, Esq., for the respondent.

The Commissioner determined a deficiency in the petitioner's 1952 income and excess profits taxes in the amount of $1,162,933.30. Certain adjustments made by the Commissioner were not contested and the Commissioner concedes that he erred in making certain other adjustments.

The sole issue for decision is whether the Commissioner erred in taxing to the petitioner net income from its former business, which business, during the taxable period, was carried on by a corporation which had purchased all of the petitioner's stock pursuant to an arrangement whereby the petitioner was to be liquidated as soon as possible and all of its regular business activities were taken over by the purchasing corporation as of the stock purchase date.

OPINION.

TIETJENS, Judge:

The facts as recited by counsel for the petitioner in his opening statement to the Court have been stipulated to be the facts. They are so found and are incorporated herein by this reference.

The petitioner, the T. V. D. Co., is an Ohio corporation having its principal office in Cincinnati, Ohio. It was originally known as the DuBois Co. The petitioner had, for a number of years prior to April 30, 1952, been engaged...

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