Opinion
No. 9931.
Argued June 9, 1949.
Decided June 20, 1949.
Appeal from the Tax Court of the United States.
Petition by the International Investment Corporation (name later changed to International Investing Corporation, and originally General Water Gas and Electric Company), opposed by the Commissioner of Internal Revenue, to review a decision of the Tax Court, 11 T.C. 678, redetermining a deficiency in income taxes.
Decision of the Tax Court affirmed.
David Stock, New York City, for petitioner.
Carlton Fox, Washington, D.C. (Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst. to the Atty. Gen., on the brief), for respondent.
Before MARIS, GOODRICH and KALODNER, Circuit Judges.
This is a petition to review a decision of the Tax Court that a loss claimed by the petitioner upon the complete liquidation of Portage Water Company, a wholly owned subsidiary, was not recognizable for income tax purposes under Section 112(b)(6) of the Internal Revenue Code, 26 U.S.C.A. § 112(b)(6). The property received by the petitioner upon the liquidation of its subsidiary consisted wholly of cash. Upon the authority of Tri-Lakes S.S. Co. v. Commissioner of Internal Revenue, 6 Cir. 1945, 146 F.2d 970, and for the reasons stated by the Tax Court in its opinion in the present case filed by Judge Kern, 11 T.C. 678, the decision of the Tax Court will be affirmed.