Legal Opinion

W A G E, Inc. v. Commissioner

United States Tax Court

Decided November 18, 1952No. Docket No. 31630Published

1. Petitioner, a corporation organized under the laws of New York, entered into an agreement with the stockholders of Corporation A on August 31, 1943, to transfer their stock in A for stock of petitioner. The agreement was to be null and void unless approved by the Federal Communications Commission. The plan was approved by the Commission, the stock was exchanged, Corporation A was merged into petitioner and dissolved, and all the assets of A were taken over by petitioner.

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1. Petitioner, a corporation organized under the laws of New York, entered into an agreement with the stockholders of Corporation A on August 31, 1943, to transfer their stock in A for stock of petitioner. The agreement was to be null and void unless approved by the Federal Communications Commission. The plan was approved by the Commission, the stock was exchanged, Corporation A was merged into petitioner and dissolved, and all the assets of A were taken over by petitioner. Held, the transaction achieved a substantial business purpose, and the principal purpose of the merger was not to avoid…

1Opinion of the Court

W A G E, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

W A G E, Inc. v. Commissioner

Docket No. 31630

United States Tax Court

19 T.C. 249; 1952 U.S. Tax Ct. LEXIS 43;

November 18, 1952, Promulgated

Decision will be entered under Rule 50.

1. Petitioner, a corporation organized under the laws of New York, entered into an agreement with the stockholders of Corporation A on August 31, 1943, to transfer their stock in A for stock of petitioner. The agreement was to be null and void unless approved by the Federal Communications Commission. The plan was approved by the Commission, the…

2Cases cited7 opinions

  1. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
  2. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. Commodores Point Terminal Corp. v. CommissionerUnited States Tax Court · 1948
  4. American Wire Fabrics Corp. v. CommissionerUnited States Tax Court · 1951
  5. W A G E, Inc. v. CommissionerUnited States Tax Court · 1952

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