United States Tax Court August 7, 1945, Docket Nos. 1471, 1472 (Fairfield S.S. Corp. v. Commissioner)

lead-opinion

OPINION.

Disney, Judge-.

The first question propounded to us is simple: Was sale of the Maine made by Fairfield, or by Atlantic after acquisition of this ship by liquidation of Fairfield? In our opinion it was made by Fairfield and the agreed gain was property taxed to that corporation. This conclusion we consider proper under Commissioner v. Court Holding Co., 324 U. S.