Bateman v. Commissioner
United States Tax Court
Upon the merger of two corporations, petitioner exchanged his common stock in one for common stock and common stock purchase warrants in the surviving corporation.
Read the full summary
Upon the merger of two corporations, petitioner exchanged his common stock in one for common stock and common stock purchase warrants in the surviving corporation. The merger was a tax-free reorganization within the provisions of section 368(a), I.R.C. 1954. Held: 1. The warrants were not stock within the meaning of section 354(a)(1), I.R.C. 1954, and therefore constituted "other property" within the meaning of section 356(a), I.R.C. 1954. 2. The exchange did not have the effect of the distribution of a dividend under the provisions of section 356(a)(2), I.R.C. 1954.
1Opinion of the Court
William H. Bateman and Annabelle P. Bateman, Petitioners, v. Commissioner of Internal Revenue, Respondent
Bateman v. Commissioner
Docket No. 93310
United States Tax Court
40 T.C. 408; 1963 U.S. Tax Ct. LEXIS 114;
May 27, 1963, Filed
Decision will be entered under Rule 50.
Upon the merger of two corporations, petitioner exchanged his common stock in one for common stock and common stock purchase warrants in the surviving corporation. The merger was a tax-free reorganization within the provisions of section 368(a), I.R.C. 1954. Held:
1. The warrants were not stock within the meaning of section…
2Cases cited13 opinions
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Groman v. CommissionerSupreme Court of the United States · 1937
8 more not listed; retrieve them via the Exa API.