Legal Opinion

Harrison v. Commissioner

United States Board of Tax Appeals

Decided June 19, 1934No. Docket No. 66193Published

The H corporation transferred all of its assets (except amounts reserved and shortly thereafter paid for taxes, etc.), to the R corporation for preferred shares of the latter, a statutory reorganization, and H agreed, pursuant to the plan of reorganization, to distribute to its shareholders the preferred shares of R to be received by it and to wind up its affairs and dissolve.

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The H corporation transferred all of its assets (except amounts reserved and shortly thereafter paid for taxes, etc.), to the R corporation for preferred shares of the latter, a statutory reorganization, and H agreed, pursuant to the plan of reorganization, to distribute to its shareholders the preferred shares of R to be received by it and to wind up its affairs and dissolve. Such shares were distributed to the shareholders of H without surrender by them of their shares of H, and some months later H was dissolved. Held, that the gain realized by a shareholder of H from the distribution may…

1Opinion of the Court

JAMES M. HARRISON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Harrison v. Commissioner

Docket No. 66193.

United States Board of Tax Appeals

30 B.T.A. 966; 1934 BTA LEXIS 1244;

June 19, 1934, Promulgated

The H corporation transferred all of its assets (except amounts reserved and shortly thereafter paid for taxes, etc.), to the R corporation for preferred shares of the latter, a statutory reorganization, and H agreed, pursuant to the plan of reorganization, to distribute to its shareholders the preferred shares of R to be received by it and to wind up its affairs and dissolve. Such…

2Cases cited5 opinions

  1. Burnet v. BrooksSupreme Court of the United States · 1933
  2. Boehringer v. CommissionerUnited States Board of Tax Appeals · 1933
  3. J. M. Harrison, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Winston Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Harrison v. CommissionerUnited States Board of Tax Appeals · 1934

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