Case v. Commissioner
United States Board of Tax Appeals
1. In 1928, pursuant to contract between stockholders, A corporation was divided by the formation of B corporation, and transfer to B, in return for its stock, of a part of the assets of A proportionate to the stock of petitioner, stockholder therein, who exchanged his stock in A for the stock of B. The assets of A were largely divided between A and B in 1928, but final adjustment was not made and actual change of stock did not take place until 1931. Held: (1) There was no…
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1. In 1928, pursuant to contract between stockholders, A corporation was divided by the formation of B corporation, and transfer to B, in return for its stock, of a part of the assets of A proportionate to the stock of petitioner, stockholder therein, who exchanged his stock in A for the stock of B. The assets of A were largely divided between A and B in 1928, but final adjustment was not made and actual change of stock did not take place until 1931. Held: (1) There was no reorganization within the meaning of section 112(i)(1)(B) of the Revenue Act of 1928, since the object of the contract…
1Opinion of the Court
PAUL L. CASE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FANNIE I. CASE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Case v. Commissioner
Docket Nos. 73767, 73768.
United States Board of Tax Appeals
37 B.T.A. 365; 1938 BTA LEXIS 1047;
February 18, 1938, Promulgated
1. In 1928, pursuant to contract between stockholders, A corporation was divided by the formation of B corporation, and transfer to B, in return for its stock, of a part of the assets of A proportionate to the stock of petitioner, stockholder therein, who exchanged his stock in A for the stock of B. The…
2Cases cited1 opinion
- Case v. CommissionerUnited States Board of Tax Appeals · 1938