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R. M. SMITH, INC. v. C. I. R.

No. 78-1442.

591 F.2d 248 (1979)

R. M. SMITH, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided January 26, 1979.

Attorney(s) appearing for the Case

Kenneth P. Simon, Reed, Smith, Shaw & McClay, Pittsburgh, Pa., for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Jonathan S. Cohen, Richard D. Buik, Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before ROSENN, GARTH and HIGGINBOTHAM, Circuit Judges.

OPINION OF THE COURT

ROSENN, Circuit Judge.

The issues raised on this appeal reflect some of the subtle tax hazards lurking in corporate liquidations. The issues turn on the application of section 334(b)(2) of the Internal Revenue Code of 1954, 26 U.S.C. § 334(b)(2) (1976), dealing with the basis of property received in liquidation of a subsidiary. Section 334(b)(2) provides that "[i]f property is received by a corporation in a distribution in complete...

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