Green v. Commissioner
United States Board of Tax Appeals
The evidence establishes that stock and debentures of a new corporation, acquired in exchange for stock of an old corporation in a nontaxable reorganization, had no market value.
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The evidence establishes that stock and debentures of a new corporation, acquired in exchange for stock of an old corporation in a nontaxable reorganization, had no market value. Held, that because of the lack of market value, no allocation of basis can be made between the new stock and debentures and no gain is to be recognized on a transaction whereby the petitioners exchanged part of their new stock for the cancellation of indebtedness in amounts less than the basis of the old stock.
1Opinion of the Court
H. A. GREEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
CLARKE E. DYE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Green v. Commissioner
Docket Nos. 74910, 74911.
United States Board of Tax Appeals
33 B.T.A. 824; 1935 BTA LEXIS 694;
December 31, 1935, Promulgated
The evidence establishes that stock and debentures of a new corporation, acquired in exchange for stock of an old corporation in a nontaxable reorganization, had no market value. Held, that because of the lack of market value, no allocation of basis can be made between the new stock and debentures and no…
2Cases cited3 opinions
- Axton v. CommissionerUnited States Board of Tax Appeals · 1935
- Green v. CommissionerUnited States Board of Tax Appeals · 1935
- Tricou v. CommissionerUnited States Board of Tax Appeals · 1932