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Commissioner Vs. Clark
Cites for this judgment
- US Supreme Court
- Mar 22, 1989
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U.S. 726 (1989) U.S. Supreme Court Commissioner v. ClarkSearch
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U.S. 726 (1989) Commissioner of Internal Revenue v. ClarkSearch
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cash payment in exchange for a portion of his stock was taxable as a dividend. In the two earlier cases, Commissioner v. EstateSearch
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of Bedford, 325 U. S. 283 (1945), and United States v. DavisSearch
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Id. at 140. Under the test advocated by the Commissioner and given voice in Shimberg v. UnitedSearch
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The second test, urged by the taxpayer and finding support in Wright v. UnitedSearch
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by the Court of Appeals for the Fourth Circuit is in conflict with the decision of the Fifth Circuit in Shimberg v. UnitedSearch
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see, e.g., Rev.Rul. 75-447, 1975-2 Cum.Bull. 113, and that we have expressly sanctioned, see Minnesota Tea Co. v. HelveringSearch
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Commissioner v. CourtSearch
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we usually read the exception narrowly in order to preserve the primary operation of the provision. See Phillips, Inc. v. WallingSearch
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merely 'a continuance of the proprietary interests in the continuing enterprise under modified corporate form.' Lewis v. CommissionerSearch
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United States v. DavisSearch
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equivalency' is whether the distribution is proportionate to the shareholders' stock interests ( United States v. DavisSearch
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distribution is a 'meaningful reduction of the shareholder's proportionate interest in the corporation.' United States v. DavisSearch
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developed as a result of some imprecise language in our decision in Commissioner v. EstateSearch
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See Rev.Rul. 56-220, 1956-1 Cum.Bull.191. Commentators, see, e.g., Darrel, The Scope of Commissioner v. BedfordSearch
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The Blunt Toe of the Automatic Rule, 20 Tax L.Rev. 573 (1965), and courts, see, e.g., Hawkinson v. CommissionerSearch
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Idaho Power Co. v. UnitedSearch
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reorganizations) that involve the exchange of stock or securities solely for other stock or securities. See Paulsen v. CommissionerSearch
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to Clark had the effect of a distribution of a dividend. We supplied the straightforward answer in United States v. DavisSearch
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U.S. Supreme Court Commissioner v. ClarkSearch
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Commissioner of Internal Revenue v. ClarkSearch
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Commissioner v. EstateSearch
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and United States v. DavisSearch
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Shimberg v. UnitedSearch
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Wright v. UnitedSearch
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Minnesota Tea Co. v. HelveringSearch
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See Phillips, Inc. v. WallingSearch
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Lewis v. CommissionerSearch
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United States v. DavisSearch
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Darrel, The Scope of Commissioner v. BedfordSearch
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Hawkinson v. CommissionerSearch
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Idaho Power Co. v. UnitedSearch
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See Paulsen v. CommissionerSearch
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