Legal Opinion

Bamberger v. Commissioner

United States Board of Tax Appeals

Decided February 23, 1933No. Docket Nos. 62578-62595Published

1. STOCK DISTRIBUTION - BASIS OF COST TO OLD AND NEW SHARES. Where petitioners were the shareholders of B Company, and B Company caused A Company and N Company and C Company to be organized and transferred a good part of its assets, consisting of common stocks and securities of other corporations, to A, N, and C Companies, for which said companies issued all their shares to B Company, which shares were in turn distributed by B Company to petitioners as stockholders of B…

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1. STOCK DISTRIBUTION - BASIS OF COST TO OLD AND NEW SHARES. Where petitioners were the shareholders of B Company, and B Company caused A Company and N Company and C Company to be organized and transferred a good part of its assets, consisting of common stocks and securities of other corporations, to A, N, and C Companies, for which said companies issued all their shares to B Company, which shares were in turn distributed by B Company to petitioners as stockholders of B Company, and where A Company and N Company soon thereafter liquidated by distributing all their assets, consisting of shares…

1Opinion of the Court

BERTHA G. BAMBERGER, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Bamberger v. Commissioner

Docket Nos. 62578-62595.

United States Board of Tax Appeals

27 B.T.A. 785; 1933 BTA LEXIS 1306;

February 23, 1933, Promulgated

1. STOCK DISTRIBUTION - BASIS OF COST TO OLD AND NEW SHARES. Where petitioners were the shareholders of B Company, and B Company caused A Company and N Company and C Company to be organized and transferred a good part of its assets, consisting of common stocks and securities of other corporations, to A, N, and C Companies, for which said companies issued all…

2Cases cited10 opinions

  1. Nichols v. CoolidgeSupreme Court of the United States · 1927
  2. Blodgett v. HoldenSupreme Court of the United States · 1927
  3. Arizona Grocery Co. v. Atchison, Topeka & Santa Fe Railway Co.Supreme Court of the United States · 1932
  4. Untermyer v. AndersonSupreme Court of the United States · 1928
  5. Shwab v. DoyleSupreme Court of the United States · 1922

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