Legal Opinion

Barker v. Commissioner

United States Board of Tax Appeals

Decided July 11, 1933No. Docket Nos. 51102, 51103, 51104Published

1. Upon the record, held, that the transfer by the Columbia River Packers Association of its assets to the Columbia River Packers Association, Inc., for $1,578,600 and 17,540 shares of no par common stock of the Columbia River Packers Association, Inc., constituted a "reorganization" within the provisions of section 203 of the Revenue Act of 1924. 2. The fair market value of the no par value common stock of the Columbia River Packers Association, Inc., as of the date of…

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1. Upon the record, held, that the transfer by the Columbia River Packers Association of its assets to the Columbia River Packers Association, Inc., for $1,578,600 and 17,540 shares of no par common stock of the Columbia River Packers Association, Inc., constituted a "reorganization" within the provisions of section 203 of the Revenue Act of 1924. 2. The fair market value of the no par value common stock of the Columbia River Packers Association, Inc., as of the date of issuance to the Columbia River Packers Association, determined.

1Opinion of the Court

FRED BARKER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

EDWARD W. THOMPSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

W. L. THOMPSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Barker v. Commissioner

Docket Nos. 51102, 51103, 51104.

United States Board of Tax Appeals

28 B.T.A. 657; 1933 BTA LEXIS 1089;

July 11, 1933, Promulgated

1. Upon the record, held, that the transfer by the Columbia River Packers Association of its assets to the Columbia River Packers Association, Inc., for $1,578,600 and 17,540 shares of no par common stock of the Columbia…

2Cases cited5 opinions

  1. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  2. Williamson v. BerrySupreme Court of the United States · 1850
  3. Corbett v. BurnetCourt of Appeals for the D.C. Circuit · 1931
  4. Pinellas Ice & Cold Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Barker v. CommissionerUnited States Board of Tax Appeals · 1933

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