Walsh Holyoke Steam Boiler Works, Inc. v. Commissioner
United States Tax Court
The amount of debenture bonds and notes which were purchased by one of petitioner's stockholders at a large discount and paid in to petitioner, in a recapitalization, in exchange for new shares of stock and new debenture bonds, held, not includible in equity invested capital in the absence of any showing as to what portion of the amount of the old obligations was paid in for stock and what portion for bonds, or any facts upon which such an allocation might be made.
1Opinion of the Court
Walsh Holyoke Steam Boiler Works, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Walsh Holyoke Steam Boiler Works, Inc. v. Commissioner
Docket No. 4696
United States Tax Court
5 T.C. 814; 1945 U.S. Tax Ct. LEXIS 75;
September 27, 1945, Promulgated
Decision will be entered under Rule 50.
The amount of debenture bonds and notes which were purchased by one of petitioner's stockholders at a large discount and paid in to petitioner, in a recapitalization, in exchange for new shares of stock and new debenture bonds, held, not includible in equity invested capital in the absence of any…
2Cases cited2 opinions
- Liberty Mirror Works v. CommissionerUnited States Tax Court · 1944
- Walsh Holyoke Steam Boiler Works, Inc. v. CommissionerUnited States Tax Court · 1945