Winston Bros. Co. v. Commissioner
United States Board of Tax Appeals
In 1928 petitioner exchanged 1,116 shares of its preferred stock and 1,803 shares of its common stock for all the business and assets of another corporation, pursuant to a plan of reorganization.
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In 1928 petitioner exchanged 1,116 shares of its preferred stock and 1,803 shares of its common stock for all the business and assets of another corporation, pursuant to a plan of reorganization. At the time of exchange, petitioner owned approximately 68 percent of the common stock of the transferor corporation, and immediately thereafter the latter corporation distributed among its stockholders in final liquidation the shares of petitioner's common stock acquired in exchange for its original assets. Petitioner received back 1,232 shares of its own common stock as a liquidating dividend, and…
1Opinion of the Court
OPINION.
Trammell :
This is a proceeding for the redetermination of a deficiency in income tax for the year 1928 in the amount, of $21,092.54
Three errors were assigned in the petition, but at the hearing petitioner waived two of the assignments, leaving for consideration here only the allegation that “ The Commissioner erred in computing a profit on stock or a liquidation of $147,114.72,” which allegation was denied by the respondent in his answer.
This proceeding was heard on March 9, 1933, and thereafter on August 23, 1933, the Board’s first report was promulgated and published at 28 B.T.A.…
2Cases cited1 opinion
- Houghton & D. Co. v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by5 opinions
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- Harrison v. CommissionerUnited States Board of Tax Appeals · 1934
- Harrison v. CommissionerUnited States Board of Tax Appeals · 1934
- Winston Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1934