Edward Sec. Corp. v. Commissioner
United States Board of Tax Appeals
Section 204(a)(8) of the Revenue Acts of 1924 and 1926, and section 113(a)(8) of the Revenue Act of 1928, requiring cost to transferor to be used as basis for determining gain or loss to transferee corporation upon sale in 1924 to 1929, both inclusive, of property acquired by transferee corporation before the enactment of the Revenue Act of 1924, for which it had issued in 1923 to transferor more than 80 percent of its capital stock in payment therefor, are not…
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Section 204(a)(8) of the Revenue Acts of 1924 and 1926, and section 113(a)(8) of the Revenue Act of 1928, requiring cost to transferor to be used as basis for determining gain or loss to transferee corporation upon sale in 1924 to 1929, both inclusive, of property acquired by transferee corporation before the enactment of the Revenue Act of 1924, for which it had issued in 1923 to transferor more than 80 percent of its capital stock in payment therefor, are not unconstitutional.
1Opinion of the Court
EDWARD SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Edward Sec. Corp. v. Commissioner
Docket Nos. 46874, 58941.
United States Board of Tax Appeals
32 B.T.A. 375; 1935 BTA LEXIS 955;
April 16, 1935, Promulgated
Section 204(a)(8) of the Revenue Acts of 1924 and 1926, and section 113(a)(8) of the Revenue Act of 1928, requiring cost to transferor to be used as basis for determining gain or loss to transferee corporation upon sale in 1924 to 1929, both inclusive, of property acquired by transferee corporation before the enactment of the Revenue Act of 1924, for…
2Cases cited22 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Blodgett v. HoldenSupreme Court of the United States · 1927
- Milliken v. United StatesSupreme Court of the United States · 1931
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