Legal Opinion

Redington v. Commissioner

United States Board of Tax Appeals

Decided February 29, 1932No. Docket No. 50953Published

1. During 1928 the petitioner exchanged certain shares of common stock in a Colorado corporation which he had acquired subsequent to March 1, 1913, at a cost of $40,000, with a Delaware corporation for certain shares of its common stock having a fair market value of $83,549 on the date of the exchange.

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1. During 1928 the petitioner exchanged certain shares of common stock in a Colorado corporation which he had acquired subsequent to March 1, 1913, at a cost of $40,000, with a Delaware corporation for certain shares of its common stock having a fair market value of $83,549 on the date of the exchange. By purchase and other exchanges the Delaware corporation acquired the remainder of the outstanding common stock of the Colorado corporation, but no part of the outstanding preferred stock. The Colorado corporation was not dissolved as a result of the transaction, but continued as a going…

1Opinion of the Court

THOMAS H. REDINGTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Redington v. Commissioner

Docket No. 50953.

United States Board of Tax Appeals

25 B.T.A. 707; 1932 BTA LEXIS 1486;

February 29, 1932, Promulgated

1. During 1928 the petitioner exchanged certain shares of common stock in a Colorado corporation which he had acquired subsequent to March 1, 1913, at a cost of $40,000, with a Delaware corporation for certain shares of its common stock having a fair market value of $83,549 on the date of the exchange. By purchase and other exchanges the Delaware corporation acquired the…

2Cases cited3 opinions

  1. Marr v. United StatesSupreme Court of the United States · 1925
  2. Green v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Redington v. CommissionerUnited States Board of Tax Appeals · 1932

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