J. M. Harrison, Inc. v. Commissioner
United States Board of Tax Appeals
Where petitioner, pursuant to a plan, exchanged substantially all of its assets for stock in another corporation and thereafter dissolved and distributed such stock among its stockholders, held, there was a statutory reorganization within section 112(i)(1)(A) of the Revenue Act of 1928, and the exchange constituted a nontaxable transaction within the meaning of section 112(b)(4) of that act.
1Opinion of the Court
*458OPINION.
Adams :
The petitioner, J. M. Harrison, Inc., in its income tax return reported the transaction between it and the Ross Industries Corporation as a tax-free exchange, and here contends that it constituted a reorganization and exchange of property by one corporation solely for stock in another corporation a party to the reorganization within the meaning of section 112 (i) (1) (A)' and section 112 (b) (4) of the Revenue Act of 1928. ■ (The pertinent paragraphs of the act are set out in the margin.1)
The respondent contends that it was a sale upon which gain or loss shall be recognized.
*459The…
2Cases cited2 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Minnesota Tea Co. v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by8 opinions
- Fifth Ave. Bank v. CommissionerUnited States Board of Tax Appeals · 1934
- Western Industries Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Harrison v. CommissionerUnited States Board of Tax Appeals · 1934
- Fifth Ave. Bank v. CommissionerUnited States Board of Tax Appeals · 1934
- Harrison v. CommissionerUnited States Board of Tax Appeals · 1934
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