Paulsen v. Commissioner
United States Tax Court
In 1976, petitioners exchanged "guaranty stock" in a State-chartered savings and loan association for savings accounts in a federally chartered mutual (nonstock) savings and loan association pursuant to a plan for the merger of the two associations. The savings accounts carry with them certain proprietary rights such as the right to vote, the right to pro rata distributions of earnings, and the right to share in the distribution of assets upon liquidation.
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In 1976, petitioners exchanged "guaranty stock" in a State-chartered savings and loan association for savings accounts in a federally chartered mutual (nonstock) savings and loan association pursuant to a plan for the merger of the two associations. The savings accounts carry with them certain proprietary rights such as the right to vote, the right to pro rata distributions of earnings, and the right to share in the distribution of assets upon liquidation. Held, the savings accounts constitute proprietary interests which satisfy the "continuity of interest" required in a reorganization under…
1Opinion of the Court
Harold T. and Marie B. Paulsen, Petitioners v. Commissioner of Internal Revenue, Respondent
Paulsen v. Commissioner
Docket No. 17549-79
United States Tax Court
78 T.C. 291; 1982 U.S. Tax Ct. LEXIS 130; 78 T.C. No. 21;
March 2, 1982, Filed
Decision will be entered for the petitioners.
In 1976, petitioners exchanged "guaranty stock" in a State-chartered savings and loan association for savings accounts in a federally chartered mutual (nonstock) savings and loan association pursuant to a plan for the merger of the two associations. The savings accounts carry with them certain proprietary rights such as…
2Cases cited14 opinions
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- United States v. ByrumSupreme Court of the United States · 1972
- June M. Carlberg, by Vida M. Frick, Guardian v. United StatesCourt of Appeals for the Eighth Circuit · 1960
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