Henderson Overland Co. v. Commissioner
United States Board of Tax Appeals
In the case of property acquired in exchange for stock prior to March 3, 1917, if the value thereof is clearly and substantially in excess of the par value of the stock exchanged, such excess may be treated as paid-in surplus in the computation of invested capital. Value of property acquired, determined. The petitioner acquired a lot of the value of $165,000. The lot was acquired as a site for a garage building.
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In the case of property acquired in exchange for stock prior to March 3, 1917, if the value thereof is clearly and substantially in excess of the par value of the stock exchanged, such excess may be treated as paid-in surplus in the computation of invested capital. Value of property acquired, determined. The petitioner acquired a lot of the value of $165,000. The lot was acquired as a site for a garage building. It was subsequently sold pursuant to a decree issued in a condemnation proceeding and a portion of the proceeds of the sale within 60 days after receipt was expended in the purchase…
1Opinion of the Court
APPEAL OF THE HENDERSON OVERLAND COMPANY.
Henderson Overland Co. v. Commissioner
Docket No. 4776.
United States Board of Tax Appeals
4 B.T.A. 1088; 1926 BTA LEXIS 2076;
September 27, 1926, Decided
In the case of property acquired in exchange for stock prior to March 3, 1917, if the value thereof is clearly and substantially in excess of the par value of the stock exchanged, such excess may be treated as paid-in surplus in the computation of invested capital.
Value of property acquired, determined.
The petitioner acquired a lot of the value of $165,000. The lot was acquired as a site for a garage…
2Cases cited1 opinion
- Henderson Overland Co. v. CommissionerUnited States Board of Tax Appeals · 1926