Motor Mart Trust v. Commissioner
United States Tax Court
A trust, taxable as a corporation, being insolvent, was reorganized at the behest of its bondholders under section 77 B of the Bankruptcy Act, the former bondholders becoming its stockholders.
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A trust, taxable as a corporation, being insolvent, was reorganized at the behest of its bondholders under section 77 B of the Bankruptcy Act, the former bondholders becoming its stockholders. Assuming but not deciding that section 270 of chapter X of the Chandler Act may, by section 276 (c)-3 of the same act, be applicable, it is held, following Alcazar Hotel, Inc., 1 T. C. 872, and other extant decisions of the Tax Court and of the Board of Tax Appeals, that there had not been, in the reorganization proceeding a cancellation or reduction of the debtor's indebtedness within the purview of…
1Opinion of the Court
Motor Mart Trust, Samuel L. Lowe, Charles M. Storey, Stanley R. Miller, Ernest Henderson, Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent
Motor Mart Trust v. Commissioner
Docket No. 2412
United States Tax Court
4 T.C. 931; 1945 U.S. Tax Ct. LEXIS 209;
March 5, 1945, Promulgated
Decision will be entered for the petitioner.
A trust, taxable as a corporation, being insolvent, was reorganized at the behest of its bondholders under section 77 B of the Bankruptcy Act, the former bondholders becoming its stockholders. Assuming but not deciding that section 270 of chapter X of the…
2Cases cited5 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Claridge Apartments Co. v. CommissionerSupreme Court of the United States · 1944
- Claridge Apartments Co. v. CommissionerUnited States Tax Court · 1942
- Alcazar Hotel v. CommissionerUnited States Tax Court · 1943
- Motor Mart Trust v. CommissionerUnited States Tax Court · 1945