Legal Opinion

Fellows Medical Mfg. Co. v. Commissioner

United States Board of Tax Appeals

Decided February 19, 1927No. Docket Nos. 5592, 8980Published

1. Shares of stock authorized to be issued by a corporation on March 9, 1917, were not "outstanding" on March 3, 1917. 2. In 1916 the petitioner acquired the assets of a Canadian corporation having a fair market value of $7,000,000 for $200,000 par value capital stock, with an understanding on the part of all concerned that additional shares would be issued to its stockholders as soon as the fair value of such assets had been determined and authority had been obtained for…

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1. Shares of stock authorized to be issued by a corporation on March 9, 1917, were not "outstanding" on March 3, 1917. 2. In 1916 the petitioner acquired the assets of a Canadian corporation having a fair market value of $7,000,000 for $200,000 par value capital stock, with an understanding on the part of all concerned that additional shares would be issued to its stockholders as soon as the fair value of such assets had been determined and authority had been obtained for the issuance of them. Held, that the $200,000 capital stock was issued "at a nominal value" within the meaning of section…

1Opinion of the Court

FELLOWS MEDICAL MANUFACTURING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Fellows Medical Mfg. Co. v. Commissioner

Docket Nos. 5592, 8980.

United States Board of Tax Appeals

6 B.T.A. 232; 1927 BTA LEXIS 3559;

February 19, 1927, Promulgated

1. Shares of stock authorized to be issued by a corporation on March 9, 1917, were not "outstanding" on March 3, 1917.

2. In 1916 the petitioner acquired the assets of a Canadian corporation having a fair market value of $7,000,000 for $200,000 par value capital stock, with an understanding on the part of all concerned that additional shares…

2Cases cited1 opinion

  1. Fellows Medical Manufacturing Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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