Four Twelve West Sixth Co. v. Commissioner
United States Tax Court
Pursuant to a plan of reorganization, petitioner acquired from a bondholders' protective committee certain depreciable and other assets of an insolvent corporation in exchange for 49 per cent of its common capital stock. Petitioner's remaining common stock and its outstanding preferred stock were sold for cash to outside interests.
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Pursuant to a plan of reorganization, petitioner acquired from a bondholders' protective committee certain depreciable and other assets of an insolvent corporation in exchange for 49 per cent of its common capital stock. Petitioner's remaining common stock and its outstanding preferred stock were sold for cash to outside interests. Held, petitioner's basis for depreciation is cost, which is measured by the fair market value of the stock issued for assets and the amount of liabilities assumed.
1Opinion of the Court
Four Twelve West Sixth Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Four Twelve West Sixth Co. v. Commissioner
Docket Nos. 1692, 3946
United States Tax Court
7 T.C. 26; 1946 U.S. Tax Ct. LEXIS 164;
June 6, 1946, Promulgated
Decision will be entered under Rule 50.
Pursuant to a plan of reorganization, petitioner acquired from a bondholders' protective committee certain depreciable and other assets of an insolvent corporation in exchange for 49 per cent of its common capital stock. Petitioner's remaining common stock and its outstanding preferred stock were sold for cash to…
2Cases cited1 opinion
- Four Twelve West Sixth Co. v. CommissionerUnited States Tax Court · 1946