Legal Opinion

Gross v. Commissioner

United States Board of Tax Appeals

Decided April 22, 1936No. Docket Nos. 79463-79466, 80767, 80768, 81082Published

GAIN OR LOSS - REORGANIZATION. - Where a corporation and a partnership transferred to a new corporation organized to take over and carry on the businesses then operated by the two, 80 percent of the corporate assets and 96 percent of the partnership assets, the consideration for the transfer being the issue by the new corporation of all of its capital stock to the transferors in proportion to the value of the assets conveyed, the corporation receiving less than 80 percent of…

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GAIN OR LOSS - REORGANIZATION. - Where a corporation and a partnership transferred to a new corporation organized to take over and carry on the businesses then operated by the two, 80 percent of the corporate assets and 96 percent of the partnership assets, the consideration for the transfer being the issue by the new corporation of all of its capital stock to the transferors in proportion to the value of the assets conveyed, the corporation receiving less than 80 percent of the issued stock, it is held, that the transaction did not constitute, as to the corporation, a reorganization within…

1Opinion of the Court

DAVID GROSS, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Gross v. Commissioner

Docket Nos. 79463-79466, 80767, 80768, 81082.

United States Board of Tax Appeals

34 B.T.A. 395; 1936 BTA LEXIS 702;

April 22, 1936, Promulgated

GAIN OR LOSS - REORGANIZATION. - Where a corporation and a partnership transferred to a new corporation organized to take over and carry on the businesses then operated by the two, 80 percent of the corporate assets and 96 percent of the partnership assets, the consideration for the transfer being the issue by the new corporation of all of its capital…

2Cases cited6 opinions

  1. John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
  2. Arctic Ice Machine Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Gross v. CommissionerUnited States Board of Tax Appeals · 1936
  4. Gray Printing Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  5. Green v. CommissionerUnited States Board of Tax Appeals · 1931

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