Commissioner of Internal Revenue v. Rockwood

LINDLEY, District Judge.

The Commissioner of Internal Revenue .assessed against respondent additional income taxes for the year 1930, in the amount of $3,112.60. The Board of Tax Appeals held the assessment improper. This petition for review followed.

The respondent and another owned the capital stock of one corporation, and two other individuals, that of another. On August 17, 1927, these, two corporations reorganized and delivered to their successor, General Fibre Products, Inc., all of their assets, in consideration of which the grantee delivered to the two predecessor corporations, its…