HAGEMAN v. C. I. R.

No. 31056.

446 F.2d 20 (1971)

Thomas M. HAGEMAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied July 14, 1971.


Attorney(s) appearing for the Case

Richard W. Roe, Fort Lauderdale, Fla., for petitioner-appellant.

K. Martin Worthy, Chief Counsel, Internal Revenue Service, Washington, D. C., Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Tax Division, U. S. Dept. of Justice, Bobby D. Burns, Atty., Internal Revenue Service, Washington, D. C., Robert W. Rust, U. S. Atty., Miami, Fla., Bennett N. Hollander, Richard Farber, Attys., Dept. of Justice, Tax Div., Washington, D. C., for respondent-appellee.

Before JOHN R. BROWN, Chief Judge, and COLEMAN and CLARK, Circuit Judges.


PER CURIAM:

Taxpayer contends that complete liquidation of his solely owned corporation (HBDC) was effected under 26 U.S.C.A. § 331(a)1 in 1964 rather than 1965 as held by the Tax Court. We affirm.

There is really not a significant question of law. All agree that "complete" liquidation is tested in practical terms and that the liquidation need not be literally complete.2 This is essentially a factual...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases