Williams v. Comm'r of Internal Revenue

3 Citing cases

  1. Austin v. Comm'r

    T.C. Memo. 2017-69 (U.S.T.C. Apr. 24, 2017)   Cited 1 times

    Because UMLIC S-Corp. was always an S corporation, it had no accumulated E&P. See Williams v. Commissioner, 110 T.C. 27, 30 (1998). After adding $45,714,868 to basis and making all other basis adjustments required by sections 1366-1368, each petitioner had an adjusted basis in his New UMLIC S-Corp. shares well in excess of $17.5 million.

  2. Rogers v. Commissioner

    Docket No. 22667-07 (U.S.T.C. Nov. 23, 2011)

    The AAA is intended to measure the accumulated taxable income of an S corporation that has not been distributed to the shareholders. See Williams v. Commissioner, 110 T.C. 27, 30 (1998). The portion of a distribution to a shareholder that does not exceed the AAA is a nontaxable return of capital to the extent of the shareholder's adjusted basis in S corporation stock.

  3. Fleming v. Louvers Int'l, Inc.

    2019 Ill. App. 2d 180364 (Ill. App. Ct. 2019)

    Each tax-free distribution reduces the shareholder's basis. See Williams v. Comm'r, 110 T.C. 27, 29-30 (1998). ΒΆ 23 3.