Bausch & Lomb Optical Company v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
1Opinion of the Court
MEDINA, Circuit Judge.
Petitioner Bausch & Lomb Optical Company, a New York corporation engaged in the manufacture and sale of ophthalmic products, on March 1, 1950 owned 9923% shares of the stock of its subsidiary Riggs Optical Company, or 79.9488'% of the 12,412 outstanding shares of Riggs. In order to effectuate certain operating economies, Bausch & Lomb decided to amalgamate Riggs with itself. To this end on April 22, 1950 Bausch & Lomb exchanged 105,508 shares of its unissued voting stock for all of the Riggs assets. An additional 433 shares of Bausch & Lomb stock went to 12 Riggs’…
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