Legal Opinion

Love v. Commissioner

United States Board of Tax Appeals

Decided January 24, 1939No. Docket Nos. 61768, 61770, 61771Published

A corporation was organized prior to June 7, 1927, to receive all the assets, other than cash, of B company. On June 7, the directors of B company declared a dividend in partial liquidation, payable on or before June 14, in excess of earnings accumulated after February 28, 1913. Also on June 7, an agreement was executed between B company (subject to approval of its stockholders) and A corporation for the transfer of the former's assets, except cash, in exchange for all the…

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A corporation was organized prior to June 7, 1927, to receive all the assets, other than cash, of B company. On June 7, the directors of B company declared a dividend in partial liquidation, payable on or before June 14, in excess of earnings accumulated after February 28, 1913. Also on June 7, an agreement was executed between B company (subject to approval of its stockholders) and A corporation for the transfer of the former's assets, except cash, in exchange for all the capital stock of A corporation, to be issued directly to the stockholders of B company. The agreement was approved by the…

1Opinion of the Court

R. C. LOVE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

MYRA LOVE LERMANN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

F. S. LOVE ESTATE, THE UNION TRUST COMPANY OF PITTSBURGH, REBECCA LUDWICK LOVE AND GEORGE HUTCHINSON LOVE, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Love v. Commissioner

Docket Nos. 61768, 61770, 61771.

United States Board of Tax Appeals

39 B.T.A. 172; 1939 BTA LEXIS 1057;

January 24, 1939, Promulgated

A corporation was organized prior to June 7, 1927, to receive all the assets, other than cash, of B company. On June 7,…

2Cases cited11 opinions

  1. Hellmich v. HellmanSupreme Court of the United States · 1928
  2. Groman v. CommissionerSupreme Court of the United States · 1937
  3. Helvering v. BashfordSupreme Court of the United States · 1938
  4. Claude Neon Lights v. CommissionerUnited States Board of Tax Appeals · 1937
  5. Edison Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933

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