Legal Opinion
Eldon S. Chapman v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided March 31, 1980No. 79-1336PublishedCited by 10 opinions
1Opinion of the Court
LEVIN H. CAMPBELL, Circuit Judge.
This appeal by the Internal Revenue Service from a decision of the Tax Court calls for the construction of certain corporate reorganization provisions of the Internal Revenue Code, 26 U.S.C. §§ 354(a)(1) and 368(a)(1). 1 We must decide whether the requirement of Section 368(a)(1)(B) that the acquisition of stock in one corporation by another be solely in exchange for voting stock of the acquiring corporation is met where, in related transactions, the acquiring corporation first acquires 8 percent of the acquiree’s stock for cash and then acquires more than 80…
2Cases cited28 opinions
- Norwegian Nitrogen Products Co. v. United StatesSupreme Court of the United States · 1933
- United States & Interstate Commerce Commission v. American Railway Express Co.Supreme Court of the United States · 1924
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Massachusetts Mutual Life Insurance v. LudwigSupreme Court of the United States · 1976
23 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Phyllis F. Borrell v. United States International Communications AgencyCourt of Appeals for the D.C. Circuit · 1982
- United States v. John E. Murray, Jr.Court of Appeals for the First Circuit · 1980
- Stratton v. Sioux Falls Paint & Glass (In Re Stratton)District Court, D. South Dakota · 1982
- Magnolia Surf, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1980
- Rhode Island Federation of Teachers, Afl-Cio v. John H. Norberg, Appeal of J. Fred LipkindCourt of Appeals for the First Circuit · 1980
5 more not listed; retrieve them via the Exa API.