Spirella Co. v. Commissioner
United States Tax Court
Loss sustained by petitioner-stockholder as a result of reduction in corporation's stated capital, exchange of old stock for new representing reduced capitalization, and redemption of part of new stock in exchange for cash, held, not recognizable under Internal Revenue Code, section 112 (e).
1Opinion of the Court
The Spirella Company Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent
Spirella Co. v. Commissioner
Docket No. 5030
United States Tax Court
5 T.C. 876; 1945 U.S. Tax Ct. LEXIS 72;
September 28, 1945, Promulgated
Decision will be entered for the respondent.
Loss sustained by petitioner-stockholder as a result of reduction in corporation's stated capital, exchange of old stock for new representing reduced capitalization, and redemption of part of new stock in exchange for cash, held, not recognizable under Internal Revenue Code, section 112 (e).
Paul P. Cohen, Esq., for the…
2Cases cited2 opinions
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Spirella Co. v. CommissionerUnited States Tax Court · 1945