Legal Opinion

Annis Furs, Inc. v. Commissioner

United States Tax Court

Decided November 30, 1943No. Docket No. 722Published

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. BERETTA v. COMMISSIONERUnited States Tax Court · 1942
  3. Annis Furs, Inc. v. CommissionerUnited States Tax Court · 1943
  4. De Nobili Cigar Co. v. CommissionerUnited States Tax Court · 1943

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