Hoult v. Commissioner
United States Board of Tax Appeals
During the years 1922 to 1924 each petitioner purchased over 600 shares of stock in the Morton Hotel Company, a Michigan corporation, at a price exceeding $130 a share. During the taxable year 1927 one Joseph H. Brewer organized the Grand Rapids Hotel Company, a Michigan corporation. Petitioners agreed with Brewer to sell him their stock in the Morton Hotel Company for $50 a share and buy stock in the new company with the proceeds, which was done.
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During the years 1922 to 1924 each petitioner purchased over 600 shares of stock in the Morton Hotel Company, a Michigan corporation, at a price exceeding $130 a share. During the taxable year 1927 one Joseph H. Brewer organized the Grand Rapids Hotel Company, a Michigan corporation. Petitioners agreed with Brewer to sell him their stock in the Morton Hotel Company for $50 a share and buy stock in the new company with the proceeds, which was done. Held, petitioners did not in substance exchange old stock for new within the meaning of section 203(b)(2) of the Revenue Act of 1926, but actually…
1Opinion of the Court
J. HAMPTON HOULT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MARTIN J. DREGGE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hoult v. Commissioner
Docket Nos. 45782, 45783.
United States Board of Tax Appeals
24 B.T.A. 79; 1931 BTA LEXIS 1700;
September 21, 1931, Promulgated
During the years 1922 to 1924 each petitioner purchased over 600 shares of stock in the Morton Hotel Company, a Michigan corporation, at a price exceeding $130 a share. During the taxable year 1927 one Joseph H. Brewer organized the Grand Rapids Hotel Company, a Michigan corporation. Petitioners…
2Cases cited1 opinion
- Hoult v. CommissionerUnited States Board of Tax Appeals · 1931