Kass v. Commissioner
United States Tax Court
As part of an integrated plan, TRACK, which was organized and controlled by a group owning 10.23 percent of ACRA's stock, purchased 83.95 percent of ACRA's stock and then merged ACRA into itself. Petitioner is one of 5.82 percent of ACRA's stockholders who did not sell their stock to TRACK. Upon the statutory merger of ACRA into TRACK, she received shares of TRACK in exchange for her shares of ACRA on a 1-for-1 basis.
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As part of an integrated plan, TRACK, which was organized and controlled by a group owning 10.23 percent of ACRA's stock, purchased 83.95 percent of ACRA's stock and then merged ACRA into itself. Petitioner is one of 5.82 percent of ACRA's stockholders who did not sell their stock to TRACK. Upon the statutory merger of ACRA into TRACK, she received shares of TRACK in exchange for her shares of ACRA on a 1-for-1 basis. Held: Petitioner must recognize gain realized as a result of the exchange. Where the parent's purchase of stock in its subsidiary is prearranged in relation to the subsequent…
1Opinion of the Court
May B. Kass, Petitioner v. Commissioner of Internal Revenue, Respondent
Kass v. Commissioner
Docket No. 570-70
United States Tax Court
60 T.C. 218; 1973 U.S. Tax Ct. LEXIS 129; 60 T.C. No. 26;
May 16, 1973, Filed
Decision will be entered for the respondent.
As part of an integrated plan, TRACK, which was organized and controlled by a group owning 10.23 percent of ACRA's stock, purchased 83.95 percent of ACRA's stock and then merged ACRA into itself. Petitioner is one of 5.82 percent of ACRA's stockholders who did not sell their stock to TRACK. Upon the statutory merger of ACRA into TRACK, she…
2Cases cited10 opinions
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
- King Enterprises, Inc. v. The United StatesUnited States Court of Claims · 1969
- Southwest Natural Gas Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
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