Liberty Service Corp. v. Commissioner
United States Board of Tax Appeals
SALE - CORPORATION ASSETS - PROFIT TAXABLE TO SELLING CORPORATION. - After contracting to sell corporate stocks which it owned and which were at the time of the contract held by banks as collateral security for indebtedness of petitioner to them, petitioner corporation executed assignments of the stock to its stockholders, but no actual distribution of the stock was made to the stockholders.
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SALE - CORPORATION ASSETS - PROFIT TAXABLE TO SELLING CORPORATION. - After contracting to sell corporate stocks which it owned and which were at the time of the contract held by banks as collateral security for indebtedness of petitioner to them, petitioner corporation executed assignments of the stock to its stockholders, but no actual distribution of the stock was made to the stockholders. Held, that the profit resulting from the sale of the stock is taxable to petitioner, and that the efforts to consummate the transaction in such a manner as would result in no tax to the selling…
1Opinion of the Court
LIBERTY SERVICE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Liberty Service Corp. v. Commissioner
Docket Nos. 53334, 60267.
United States Board of Tax Appeals
28 B.T.A. 1067; 1933 BTA LEXIS 1048;
August 15, 1933, Promulgated
SALE - CORPORATION ASSETS - PROFIT TAXABLE TO SELLING CORPORATION. - After contracting to sell corporate stocks which it owned and which were at the time of the contract held by banks as collateral security for indebtedness of petitioner to them, petitioner corporation executed assignments of the stock to its stockholders, but no actual…
2Cases cited2 opinions
- Taylor Oil & Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Liberty Service Corp. v. CommissionerUnited States Board of Tax Appeals · 1933