Diescher v. Commissioner
United States Board of Tax Appeals
1. INCOME. - Two of the petitioners, owners of certain inventions and patents, conveyed these, in the taxable year, to a newly organized corporation in exchange for 2,500 shares of stock in the corporation and $100,000 cash. This was done with the agreement by another corporation that it would purchase 3,000 shares of the new corporation's stock for $180,000 cash. This purchase was made. All of the 5,500 shares of stock were issued on the same day.
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1. INCOME. - Two of the petitioners, owners of certain inventions and patents, conveyed these, in the taxable year, to a newly organized corporation in exchange for 2,500 shares of stock in the corporation and $100,000 cash. This was done with the agreement by another corporation that it would purchase 3,000 shares of the new corporation's stock for $180,000 cash. This purchase was made. All of the 5,500 shares of stock were issued on the same day. Held that, as to petitioners, the transaction was not within section 112(b)(5) of the Revenue Act of 1932, nor within section 112(c)(1). Therefore…
1Opinion of the Court
SAMUEL E. DIESCHER AND MRS. SAMUEL E. DIESCHER (HUSBAND AND WIFE), PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
AUGUST P. DIESCHER AND MRS. AUGUST P. DIESCHER (HUSBAND AND WIFE), PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Diescher v. Commissioner
Docket Nos. 85715, 85716.
United States Board of Tax Appeals
36 B.T.A. 732; 1937 BTA LEXIS 664;
October 26, 1937, Promulgated
1. INCOME. - Two of the petitioners, owners of certain inventions and patents, conveyed these, in the taxable year, to a newly organized corporation in exchange for 2,500 shares of stock in the…
2Cases cited13 opinions
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Crown Die & Tool Co. v. Nye Tool & MacHine WorksSupreme Court of the United States · 1923
- Tucker v. FergusonSupreme Court of the United States · 1875
- Ryan v. CarterSupreme Court of the United States · 1876
- Hershey Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
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