Roelker v. Commissioner
United States Board of Tax Appeals
1. A trust company, in which petitioner held two blocks of stock acquired at different times, reduced its capital stock from 600,000 shares to 352,000 shares in connection with a plan of reorganization. Petitioner exchanged her certificates for cash and new certificates based upon the reduced capital.
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1. A trust company, in which petitioner held two blocks of stock acquired at different times, reduced its capital stock from 600,000 shares to 352,000 shares in connection with a plan of reorganization. Petitioner exchanged her certificates for cash and new certificates based upon the reduced capital. Held, that the old stock was exchanged for stock and money in pursuance of a plan of reorganization, under section 112(c)(1), Revenue Act of 1928. 2. Prior to the taxable year the corporation changed its name and was transformed from a bank into a trust company under the laws of New York. Held,…
1Opinion of the Court
*971OPINION.
Disney:
In his determination of the deficiency the respondent found that the petitioner exchanged 3,090 shares of stock, consisting of two blocks of 1,545 shares each, acquired at different times, for 1,946.7 shares of stock in the same corporation of the value of $42,-*972340.73, or $21.75 per share, and a cash dividend of $8 per share on 3,090 shares, a total of $24,720, pursuant to a plan of reorganization under section 112 (c) (1) of the Revenue Act of 1928. He allocated one-half of the value of the stock and cash received to each block of stock, and determining that petitioner had…
2Cases cited9 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- Michigan Insurance Bank v. EldredSupreme Court of the United States · 1892
- John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
4 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Erdman v. CommissionerUnited States Tax Court · 1946
- Roelker v. CommissionerUnited States Board of Tax Appeals · 1939