Ward v. Commissioner
United States Board of Tax Appeals
1. In connection with a reorganization petitioners agreed to exchange common and preferred stocks of A corporation for amounts certain of common stock of B corporation, which further agreed to repurchase upon petitioners' demand, all of its stock exchanged for A preferred stock and a part of its stock exchanged for A common stock. Shortly after the contract was made petitioners have notice that repurchase would be demanded.
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1. In connection with a reorganization petitioners agreed to exchange common and preferred stocks of A corporation for amounts certain of common stock of B corporation, which further agreed to repurchase upon petitioners' demand, all of its stock exchanged for A preferred stock and a part of its stock exchanged for A common stock. Shortly after the contract was made petitioners have notice that repurchase would be demanded. Thereafter, the stocks were delivered in accordance with the contract and two days later corporation B made repurchases. Held, notwithstanding the result ultimately…
1Opinion of the Court
OPINION.
GooDRicii:
In these proceedings, which were consolidated for hearing, petitioners assail the following deficiencies in income tax for 1929:
Daisy M. Ward_ $107.35
Chris M. Peterson- 346. 57
Earl W. Ward_1, 319. 41
Estate of K. P. Ward_J_ 7,224. 73
Emerson C. Ward_ 124. 89
Charles H. Watson_4, 314. 60
Broadly, the issue relates to the amount of taxable gain derived by petitioners upon the disposition of their stock of the Ward Dry Milk Go., a corporation of Waseca, Minnesota. The facts clearly appear in the various written exhibits in evidence and from, short additional testimony. Since they…
2Cases cited4 opinions
- Rockefeller v. United StatesSupreme Court of the United States · 1921
- Peabody v. EisnerSupreme Court of the United States · 1918
- Tillotson Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Estate of Metcalf v. CommissionerUnited States Board of Tax Appeals · 1928
3Cited by16 opinions
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Penrod v. CommissionerUnited States Tax Court · 1987
- International Tel. & Tel. Corp. etc. v. CommissionerUnited States Tax Court · 1981
- McDonald's of Zion, 432, Ill., Inc. v. CommissionerUnited States Tax Court · 1981
- Fifth Ave. Bank v. CommissionerUnited States Board of Tax Appeals · 1934
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