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Bentsen v. Phinney
United States District Court for the Southern District of Texas
199 F.Supp. 363 (1961)
Facts
The Bentsen family (plaintiff) controlled three corporations. The three corporations merged, forming a life-insurance company. The shareholders of the new company were the same shareholders of the three merging corporations. The shareholders reported a taxable gain on the transaction and filed for a refund, claiming the transaction qualified for nonrecognition as a reorganization. The Internal Revenue Service (IRS) denied the corporate reorganization, citing a lack of continuity of business enterprise. The Bentsen family filed a claim in the United States District Court for the Southern District of Texas.
Rule of Law
Issue
Holding and Reasoning (Garza, J.)
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