Legal Opinion

Golden Cycle Corp. v. Commissioner

United States Board of Tax Appeals

Decided November 9, 1929No. Docket No. 16378Published

On January 15, 1917, corporation A formed corporation B with a capital stock of $100,000, and transferred to it a part of its (A's) assets having a value of $1,344,355.28, in consideration for the issuance to A corporation of the entire capital stock of B corporation, thereby creating an affiliation of the two corporations.

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On January 15, 1917, corporation A formed corporation B with a capital stock of $100,000, and transferred to it a part of its (A's) assets having a value of $1,344,355.28, in consideration for the issuance to A corporation of the entire capital stock of B corporation, thereby creating an affiliation of the two corporations. The statutory cost for invested capital purposes to A corporation of the assets transferred to B corporation was much less than their value on January 15, 1917. Held that by the transaction in question the consolidated group merely acquired a part of its own capital stock…

1Opinion of the Court

THE GOLDEN CYCLE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Golden Cycle Corp. v. Commissioner

Docket No. 16378.

United States Board of Tax Appeals

18 B.T.A. 118; 1929 BTA LEXIS 2135;

November 9, 1929, Promulgated

On January 15, 1917, corporation A formed corporation B with a capital stock of $100,000, and transferred to it a part of its (A's) assets having a value of $1,344,355.28, in consideration for the issuance to A corporation of the entire capital stock of B corporation, thereby creating an affiliation of the two corporations. The statutory cost for invested…

2Cases cited4 opinions

  1. American Bond & Mortg. Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Middlesex Ice Co. v. CommissionerUnited States Board of Tax Appeals · 1927
  3. Grand Rapids Dry Goods Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  4. Golden Cycle Corp. v. CommissionerUnited States Board of Tax Appeals · 1929

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