Philadelphia Transp. Co. v. Commissioner
United States Tax Court
A plan of reorganization under section 77-B of the Bankruptcy Act, approved November 14, 1939, provided for merger and consolidation of 65 companies previously constituting the Philadelphia Rapid Transit Co. System into a new company to be incorporated, the petitioner herein.
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A plan of reorganization under section 77-B of the Bankruptcy Act, approved November 14, 1939, provided for merger and consolidation of 65 companies previously constituting the Philadelphia Rapid Transit Co. System into a new company to be incorporated, the petitioner herein. It also provided that the new company, upon incorporation, should issue to holders of stock and stock trust certificates of certain of the merged companies, its 3 per cent-6 per cent consolidated mortgage bonds dated January 1, 1939, and bearing interest from that date. Petitioner's corporate existence began on January…
1Opinion of the Court
Philadelphia Transportation Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Philadelphia Transp. Co. v. Commissioner
Docket No. 9893
United States Tax Court
9 T.C. 1018; 1947 U.S. Tax Ct. LEXIS 23;
November 28, 1947, Promulgated
Decision will be entered under Rule 50.
A plan of reorganization under section 77-B of the Bankruptcy Act, approved November 14, 1939, provided for merger and consolidation of 65 companies previously constituting the Philadelphia Rapid Transit Co. System into a new company to be incorporated, the petitioner herein. It also provided that the new company,…
2Cases cited5 opinions
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- Koppers Co. v. CommissionerUnited States Tax Court · 1944
- Ernst Kern Co. v. CommissionerUnited States Tax Court · 1942
- Rodney, Inc. v. CommissionerUnited States Tax Court · 1943
- Philadelphia Transp. Co. v. CommissionerUnited States Tax Court · 1947