Legal Opinion

Joseph v. Commissioner

United States Board of Tax Appeals

Decided March 24, 1927No. Docket Nos. 3091-3093Published

A corporation of which the petitioners were stockholders was legally dissolved in 1919 and the assets were received by the directors (who constituted the stockholders) as trustees in liquidation; in 1920 they sold the assets to a partnership (composed of the three principal stockholders) at their book value, receiving in payment therefor four promissory notes.

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A corporation of which the petitioners were stockholders was legally dissolved in 1919 and the assets were received by the directors (who constituted the stockholders) as trustees in liquidation; in 1920 they sold the assets to a partnership (composed of the three principal stockholders) at their book value, receiving in payment therefor four promissory notes. Held, that the petitioners derived income measured by the difference between the cost of their shares and the book value at date of dissolution of the corporation.

1Opinion of the Court

JOSEPH JOSEPH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

WELLS FARGO BANK & UNION TRUST CO., AND IRVING GOLLOBER, EXECUTORS, ESTATE OF JULIUS GOLLOBER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

IRVING GOLLOBER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Joseph v. Commissioner

Docket Nos. 3091-3093.

United States Board of Tax Appeals

6 B.T.A. 595; 1927 BTA LEXIS 3468;

March 24, 1927, Promulgated

A corporation of which the petitioners were stockholders was legally dissolved in 1919 and the assets were received by the directors (who constituted…

2Cases cited1 opinion

  1. Joseph v. CommissionerUnited States Board of Tax Appeals · 1927

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