Simms v. Commissioner
United States Board of Tax Appeals
1. Petitioner transferred oil leases to a newly organized corporation in exchange for its entire capital stock, all of which stock, pursuant to prior agreements contemplating the creation of a second corporation to develop the leases, was thereafter transferred to the second corporation in exchange for part of its stock, and the remaining stock of the second corporation was sold to or through syndicate participants for cash.
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1. Petitioner transferred oil leases to a newly organized corporation in exchange for its entire capital stock, all of which stock, pursuant to prior agreements contemplating the creation of a second corporation to develop the leases, was thereafter transferred to the second corporation in exchange for part of its stock, and the remaining stock of the second corporation was sold to or through syndicate participants for cash. Held, under the Revenue Act of 1918, (a) that the first exchange was a separate and completed transaction, the gain or loss upon which must be computed on the difference…
1Opinion of the Court
E. F. SIMMS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Simms v. Commissioner
Docket Nos. 19175, 19791.
United States Board of Tax Appeals
28 B.T.A. 988; 1933 BTA LEXIS 1053;
August 11, 1933, Promulgated
1. Petitioner transferred oil leases to a newly organized corporation in exchange for its entire capital stock, all of which stock, pursuant to prior agreements contemplating the creation of a second corporation to develop the leases, was thereafter transferred to the second corporation in exchange for part of its stock, and the remaining stock of the second corporation was sold…
2Cases cited29 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- United States v. AndersonSupreme Court of the United States · 1926
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Palmer v. BenderSupreme Court of the United States · 1932
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
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