26 U.S.C. § 341
Repealed. Pub. L. 108–27, title III, § 302(e)(4)(A), May 28, 2003, 117 Stat. 763]
[repealed]
Notes of Decisions
Cited in 16
cases, 1938–1985 · leading case: E. Keith Owens v. Comm'r of Internal Revenue, 568 F.2d 1233 (6th Cir. 1977).
E. Keith Owens v. Comm'r of Internal Revenue, 568 F.2d 1233 (6th Cir. 1977). “Taxpayer’s accountants were concerned that collapsible corporation problems under 26 U.S.C. § 341 might arise if the sale of stock took place before all of the cattle were sold.”
Rolland L. King & Arlene P. King v. United States, 641 F.2d 253 (5th Cir. 1981). “” 26 U.S.C. § 341 (b)(1). Based on the foregoing definition, the taxpayer first argues that the utility corporations in question were formed principally for the operation of the utility franchises, not for the construction of property.”
Florenz R. Ourisman & Betty Joan Ourisman v. Comm'r of Internal Revenue, 760 F.2d 541 (4th Cir. 1985). “06 gain on liquidation was ordinary income under 26 U.S.C. § 341 (IRC § 341). 6 . Taxpayers do not contend that the corporate entity should be disregarded for tax purposes because it was a mere passive dummy of its shareholders.”
Edward Weil & Dorothy Weil v. Comm'r of Internal Revenue, 252 F.2d 805 (2d Cir. 1958). “Its somewhat similar counterpart is found in the 1954 Code at 26 U.S.C.A. § 341 . In an opinion by Judge Opper, reported at 28 T.”
Comm'r of Internal Revenue v. James B. Kelley & Lena S. Kelley, & John Waltman & Doris Waltman, 293 F.2d 904 (5th Cir. 1961). “In the 1954 Code Section 341, 26 U.S.C.A. § 341 is the counterpart of Section 117(m).”
United States v. Harold W. Ivey & Mrs. Virginia Ivey, Harold W. Ivey & Mrs. Virginia Ivey v. United States, 294 F.2d 799 (5th Cir. 1961). “He argues that Section 341 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 341 , defining “collapsible corporations” is inapplicable when a taxpayer is entitled to capital gains treatment without benefit of incorporating.”
Kelley v. Comm'r, 32 T.C. 135 (Tax Ct. 1959). “Its counterpart is found in the Revenue Act of 1954 ( 26 U.S.C.A. § 341 (b)(1)(A) ) in the phrase "a substantial part of the taxable income.”
Lincoln Sav. & Loan Ass'n v. Comm'r of Internal Revenue, 422 F.2d 90 (9th Cir. 1970). “26 U.S.C. § 341 (1964). Accordingly, to give consideration to the possibilities of reimbursement because of liquidation or receivership is inconsistent with this principle.”
Chicago Tel. Supply Co. v. United States, 23 F. Supp. 471 (Ct. Cl. 1938). “The excess-profits tax’ was computed pursuant to section 702 of the Revenue Act of 1934, 26 U.S.C.A. § 341 , as 5 per cent of the income in excess of 12% per cent of the declared value of capital stock.”
Levenson v. United States, 157 F. Supp. 244 (N.D. Ala. 1957). “Its counterpart is found in the Revenue Act of 1954 ( 26 U.S.C.A. § 341 (b) (1) (A)) in the phrase “a substantial part of the taxable income.”
Honaker, Drlg., Inc. v. Koehler, 190 F. Supp. 287 (D. Kan. 1960). “26 U.S.C.A. § 341 (b). The deficiency which was assessed was paid by the individual plaintiffs as the transferees of the corporation’s assets, who then brought this action for refund pursuant to 28 U.”
Twentieth Century-Fox Film Corp. v. Comm'r of Internal Revenue, 372 F.2d 281 (2d Cir. 1967). “Code § 341(a), 26 U.S.C. § 341 (a). Eventually, however, the Service made it known that a ruling favorable to Feldman would be made upon the condition that prior to the sale of his stock, Group sold all the rights it held in the cinema classic Streetcar.”
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