# Avco Mfg. Corp. v. Commissioner

> United States Tax Court · January 31, 1956 · 25 T.C. 975

URL: https://www.frixlaw.com/law-library/cases/4477345

## Case

- **Full name:** Avco Manufacturing Corporation v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** January 31, 1956
- **Citations:** 25 T.C. 975; 1956 U.S. Tax Ct. LEXIS 281
- **Precedential status:** Published
- **Opinion:** Dissent by Murdock
- **Judges:** Opper
- **Cited by:** 18 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4477345

## Opinion text

Murdock, J., dissenting: I do not agree that the application of section 112 (b) (6) was avoided by what transpired with relation to the 200 shares of Crosley stock. Nor am I convinced that there was not a partial liquidation within the meaning of section 115 (i) of the Revenue Act of 1934 when, in 1935, the petitioner distributed 277,785 shares of American and 138,887% shares of Colonial to its stockholders and, at the same time, reduced the par value of its stock by two-fifths.
Obper, J., agrees with this dissent.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4477345. Public record. Not legal advice.