Peabody Hotel Co. v. Commissioner
United States Tax Court
Pursuant to a plan of reorganization adopted under a section 77-B Bankruptcy Act proceeding, the insolvent debtor corporation's property was transferred to two new corporations. Approximately 13 per cent of such property (as it existed prior to such transfers) was transferred to one new corporation in recognition of the full priority rights of one class of bondholders secured by such property.
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Pursuant to a plan of reorganization adopted under a section 77-B Bankruptcy Act proceeding, the insolvent debtor corporation's property was transferred to two new corporations. Approximately 13 per cent of such property (as it existed prior to such transfers) was transferred to one new corporation in recognition of the full priority rights of one class of bondholders secured by such property. The other new corporation, petitioner, acquired all of the insolvent debtor's property to which the latter's general creditors and the other classes of bondholders could look for payment of their…
1Opinion of the Court
Peabody Hotel Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Peabody Hotel Co. v. Commissioner
Docket No. 230
United States Tax Court
7 T.C. 600; 1946 U.S. Tax Ct. LEXIS 98;
August 19, 1946, Promulgated
Decision will be entered under Rule 50.
Pursuant to a plan of reorganization adopted under a section 77-B Bankruptcy Act proceeding, the insolvent debtor corporation's property was transferred to two new corporations. Approximately 13 per cent of such property (as it existed prior to such transfers) was transferred to one new corporation in recognition of the full priority…
2Cases cited1 opinion
- Peabody Hotel Co. v. CommissionerUnited States Tax Court · 1946