Watts v. Commissioner
United States Board of Tax Appeals
The transaction herein detailed not resulting in a reorganization, gain or loss is to be recognized to petitioners.
1Opinion of the Court
*1061OPINION.
Van Fossan:
The petitioners in these proceedings contend that they exchanged all of the stock of Ferro Alloys for stock of the Vanadium Co. and bonds of Ferro Alloys guaranteed by the Vanadium Co.; that these two corporations were parties to a reorganization and that, therefore, under the provisions of section 203 (b) (2) of the Revenue Act of 1924. no gain may be recognized. The *1062respondent, on the other hand, contends that the transaction between Sloane and the Vanadium Co. was a sale by the petitioners of all of the capital stock of Ferro Alloys and that it resulted in the creation…
2Cases cited3 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- In Re Proving the Will of BergdorfNew York Court of Appeals · 1912
- Irvine v. . New York Edison Co.New York Court of Appeals · 1913
3Cited by10 opinions
- Penfield v. DavisDistrict Court, N.D. Alabama · 1952
- Ballwood Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1936
- Ballwood Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Evans v. CommissionerUnited States Board of Tax Appeals · 1934
- Averill v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1938
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