Annis Furs, Inc. v. Commissioner
United States Tax Court
The receipt in 1939 by nonresident alien shareholders of a corporation's 6 percent debentures in a nontaxable (section 112 (b) (3)) recapitalization (section 112 (g) (1) (E)) in exchange for their 6 1/2 percent preferred shares held not essentially equivalent to a dividend taxable under section 115 (g), Internal Revenue Code.
1Opinion of the Court
Annis Furs, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Annis Furs, Inc. v. Commissioner
Docket No. 722
United States Tax Court
2 T.C. 1096; 1943 U.S. Tax Ct. LEXIS 21;
November 30, 1943, Promulgated
Decision will be entered for the petitioner.
The receipt in 1939 by nonresident alien shareholders of a corporation's 6 percent debentures in a nontaxable (section 112 (b) (3)) recapitalization (section 112 (g) (1) (E)) in exchange for their 6 1/2 percent preferred shares held not essentially equivalent to a dividend taxable under section 115 (g), Internal Revenue Code.
Everett H.…
2Cases cited4 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- BERETTA v. COMMISSIONERUnited States Tax Court · 1942
- Annis Furs, Inc. v. CommissionerUnited States Tax Court · 1943
- De Nobili Cigar Co. v. CommissionerUnited States Tax Court · 1943