New Colonial Ice Co. v. Helvering

This is a controversy respecting deficiencies in the petitioner’s income taxes for 1922 and 1923.

The question presented is — where all the assets and business of an older corporation are taken over by a new corporation, specially organized for the purpose and having substantially the same capital structure, in exchange for a portion of its stock, which is distributed by the older corporation among the latter’s stockholders share for share, thereby retiring the old shares, is the new corporation entitled, notwithstanding the change in corporate identity and ownership, to have its taxable…