Georgia Sav. Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
Where the stockholders in 1928 exchanged their stock in A corporation, a party to a reorganization, for stock only in B corporation, also a party to the reorganization, and A corporation sold its real estate and part of its personal property to B corporation for a cash consideration of $200,000 and declared dividends of $200,000 out of surplus, held, that the two transactions were separate both in substance and in form, although part of a general plan; that the stockholders…
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Where the stockholders in 1928 exchanged their stock in A corporation, a party to a reorganization, for stock only in B corporation, also a party to the reorganization, and A corporation sold its real estate and part of its personal property to B corporation for a cash consideration of $200,000 and declared dividends of $200,000 out of surplus, held, that the two transactions were separate both in substance and in form, although part of a general plan; that the stockholders of A corporation exchanged stock for stock only, and not for stock and cash, and that under the provisions of section…
1Opinion of the Court
GEORGIA SAVINGS BANK & TRUST COMPANY, EXECUTOR OF THE ESTATE OF JOSEPH E. BOSTON, SR., PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Georgia Sav. Bank & Trust Co. v. Commissioner
Docket Nos. 55581-55591.
United States Board of Tax Appeals
28 B.T.A. 1153; 1933 BTA LEXIS 1043;
August 18, 1933, Promulgated
Where the stockholders in 1928 exchanged their stock in A corporation, a party to a reorganization, for stock only in B corporation, also a party to the reorganization, and A corporation sold its real estate and part of its personal property to B corporation for a cash…
2Cases cited1 opinion
- Georgia Sav. Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933