TSN LIQUIDATING CORP., INC. v. UNITED STATES

No. 78-3192.

624 F.2d 1328 (1980)

TSN LIQUIDATING CORPORATION, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

August 28, 1980.


Attorney(s) appearing for the Case

Cecil E. Munn, Harry E. Bartel, Fort Worth, Tex., for plaintiff-appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Act. Chief, App. Section, Gary R. Allen, Thomas M. Preston, Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant-appellee.

Before FAY, KRAVITCH and RANDALL, Circuit Judges.


RANDALL, Circuit Judge:

This case presents the question whether assets distributed to a corporation by its subsidiary, immediately prior to the sale by such corporation of all the capital stock of such subsidiary, should be treated, for federal income tax purposes, as a dividend or, as the district court held, as part of the consideration received from the sale of such capital stock. We hold that on the facts of this case, the assets so distributed constituted a dividend...

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