Legal Opinion

Victory Glass, Inc. v. Commissioner

United States Tax Court

Decided October 21, 1948No. Docket No. 15176Published

Bondholders of a previous corporation, pursuant to a plan for organization of a new corporation and exchange of preferred stock for bonds, accepted therefor preferred stock in petitioner, the new corporation, in the amount of par value of the bonds, and interest, after the former corporation had been placed in receivership and its assets, securing the bonds, acquired by the petitioner subject to the lien of the bonds, from the trustee for the bondholders, the purchaser of…

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Bondholders of a previous corporation, pursuant to a plan for organization of a new corporation and exchange of preferred stock for bonds, accepted therefor preferred stock in petitioner, the new corporation, in the amount of par value of the bonds, and interest, after the former corporation had been placed in receivership and its assets, securing the bonds, acquired by the petitioner subject to the lien of the bonds, from the trustee for the bondholders, the purchaser of the assets for a nominal amount at a foreclosure sale. Held, that, under section 718 (a) (2) of the Internal Revenue Code,…

1Opinion of the Court

Victory Glass, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Victory Glass, Inc. v. Commissioner

Docket No. 15176

United States Tax Court

11 T.C. 656; 1948 U.S. Tax Ct. LEXIS 53;

October 21, 1948, Promulgated

Decision will be entered for the respondent.

Bondholders of a previous corporation, pursuant to a plan for organization of a new corporation and exchange of preferred stock for bonds, accepted therefor preferred stock in petitioner, the new corporation, in the amount of par value of the bonds, and interest, after the former corporation had been placed in receivership and its…

2Cases cited7 opinions

  1. LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
  2. Difco Laboratories, Inc. v. CommissionerUnited States Tax Court · 1948
  3. Liberty Mirror Works v. CommissionerUnited States Tax Court · 1944
  4. McKay Products Corp. v. CommissionerUnited States Tax Court · 1947
  5. Brown Shoe Co. v. CommissionerUnited States Tax Court · 1948

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