Newbury v. Commissioner
United States Board of Tax Appeals
1. Where the petitioner in the reorganization of a corporation exchanged 4,999 shares of stock in the old corporation, which had a March 1, 1913, value of $4,768,965.64, for 9,998 shares of no par value common stock in the new reorganized corporation and $3,655,518.25 in cash, held, the stock in the new corporation did not have a readily realizable market value at the time received by petitioner and no taxable gain resulted from the transaction. 2. Where the petitioner filed…
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1. Where the petitioner in the reorganization of a corporation exchanged 4,999 shares of stock in the old corporation, which had a March 1, 1913, value of $4,768,965.64, for 9,998 shares of no par value common stock in the new reorganized corporation and $3,655,518.25 in cash, held, the stock in the new corporation did not have a readily realizable market value at the time received by petitioner and no taxable gain resulted from the transaction. 2. Where the petitioner filed the appropriate return required of fiduciaries, and there is no income taxable to the fiduciary, but did not disclose…
1Opinion of the Court
MOLLIE NETCHER NEWBURY, TRUSTEE OF THE ESTATE OF CHARLES NETCHER, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Newbury v. Commissioner
Docket No. 42435.
United States Board of Tax Appeals
31 B.T.A. 41; 1934 BTA LEXIS 1170;
August 9, 1934, Promulgated
1. Where the petitioner in the reorganization of a corporation exchanged 4,999 shares of stock in the old corporation, which had a March 1, 1913, value of $4,768,965.64, for 9,998 shares of no par value common stock in the new reorganized corporation and $3,655,518.25 in cash, held, the stock in the new corporation did not…
2Cases cited1 opinion
- Newbury v. CommissionerUnited States Board of Tax Appeals · 1934