J. S. Rippel & Co. v. Commissioner
United States Board of Tax Appeals
Where A corporation acquired in excess of 60 percent of the outstanding capital stock of B corporation for cash and bonds, and the latter corporation was not dissolved but continued to operate its business without modification in any way, held, there was no reorganization within the meaning of section 203(h)(1) of the Revenue Act of 1926. Held, further, the gain derived by the petitioner upon the exchange of its stock in B corporation for cash and bonds of A corporation is…
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Where A corporation acquired in excess of 60 percent of the outstanding capital stock of B corporation for cash and bonds, and the latter corporation was not dissolved but continued to operate its business without modification in any way, held, there was no reorganization within the meaning of section 203(h)(1) of the Revenue Act of 1926. Held, further, the gain derived by the petitioner upon the exchange of its stock in B corporation for cash and bonds of A corporation is recognizable for tax purposes to the extent of both the cash and the bonds so received.
1Opinion of the Court
J. S. RIPPEL & COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
J. S. Rippel & Co. v. Commissioner
Docket No. 59009.
United States Board of Tax Appeals
30 B.T.A. 1146; 1934 BTA LEXIS 1226;
June 29, 1934, Promulgated
Where A corporation acquired in excess of 60 percent of the outstanding capital stock of B corporation for cash and bonds, and the latter corporation was not dissolved but continued to operate its business without modification in any way, held, there was no reorganization within the meaning of section 203(h)(1) of the Revenue Act of 1926. Held, further, the gain…
2Cases cited1 opinion
- J. S. Rippel & Co. v. CommissionerUnited States Board of Tax Appeals · 1934