Hickok v. Commissioner
United States Tax Court
Petitioners exchanged stock for the corporation's debenture bonds pursuant to a plan of recapitalization. Held, no gain is recognized as it was a plan of reorganization within the provisions of section 112(b)(3), I.R.C. 1939, which is defined to include a plan of recapitalization in section 112(g)(1)(E), I.R.C. 1939.
1Opinion of the Court
Mulronet, Judge:
The respondent determined the following deficiencies in the petitioners’ income tax:
Docket No. Petitioner Year Deficiency
63224 63255 63256 Alan O. and Ann T. Hickok_ Eaymond T. and Sally Hickok_ H. Justine Hickok_ 1953 1953 1953 1954 $8,441.44 8,437.62 10,798.71 214.23
The issue in these consolidated cases is whether the exchange by petitioners of their stock in the Hickok Manufacturing Co., Inc., for 20-year 6 per cent debenture bonds of the same corporation qualifies as a nontaxable exchange under sections 112 (b) (3) and 112 (g) (1) (E) of the Internal Eevenue Code of 1939.
FI…
2Cases cited21 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Bazley v. CommissionerSupreme Court of the United States · 1947
16 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- McDonald's of Zion, 432, Ill., Inc. v. CommissionerUnited States Tax Court · 1981
- Lorch v. CommissionerUnited States Tax Court · 1978
- Golden Nugget, Inc. v. CommissionerUnited States Tax Court · 1984
- Johnson v. CommissionerUnited States Tax Court · 1982
- Dillard v. CommissionerUnited States Tax Court · 1961
7 more not listed; retrieve them via the Exa API.