CIR v. Court Holding Co., 33 AFTR 593, 45-1 USTC
U.S. v. Cumberland Public Service Co., 38 AFTER 978, 50-1 USTC
Why the Supreme Court reached different conclusions for cases involving similar facts & issues then list the resources that you are to analyze. Discuss what the tax case was about, how the court ruled & how it relates to the issue. How the court ruled & how it relates to the issue at hand. Was able to show that the liquidation & dissolution genuinely ended the corporation's activities & existence so that the shareholders acted on their behalf when they executed the previously contemplated sale to the cooperative. The Supreme Court would rule for the corporation being responsible for the capital gains tax. The corporation was the entity that negotiated the sale with the purchaser. The shareholders were likely not the same people running the company. The Supreme Court ruled that the corporation should not be responsible for the capital gains tax. Write 1 full page for 2 cases.
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