Hammond Iron Co. v. Commissioner
United States Board of Tax Appeals
Where a corporation in 1933 exchanged a portion of its assets for shares of its own capital stock, it sustained no loss deductible in computing its taxable net income. Helvering v. Reynolds Tobacco Co.,306 U.S. 110.
1Opinion of the Court
opinion.
Hill:
Respondent determined a deficiency in petitioner’s income tax for the year 1933 in the amount of $2,487.25, from which petitioner appeals and assigns as error the action of respondent in disallowing a deduction of $109,950.59 claimed as a capital loss resulting from the sale of a portion of petitioner’s assets to the First National Bank of Birmingham, Alabama, as trustee under the will of Morris W. Bush, deceased, in exchange for shares of petitioner’s own stock, thereafter held as treasury stock.
Petitioner is a corporation, organized under the laws of Delaware, with its…
2Cases cited1 opinion
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
3Cited by2 opinions
- Hammond Iron Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Trinity Corp. v. CommissionerUnited States Board of Tax Appeals · 1941