Alleghany Corp. v. Commissioner
United States Tax Court
During 1929 and 1930, petitioner acquired more than half of the common stock of the MissouriPacific Railroad Company. In 1933, all of the property of Missouri Pacific was placed under the jurisdiction of the Federal courts and the Interstate Commerce Commission for reorganization under section 77 of the Bankruptcy Act. The original reorganization plans of the Commission provided for a reorganization of Missouri Pacific with no value being allotted to the old common stock.
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During 1929 and 1930, petitioner acquired more than half of the common stock of the MissouriPacific Railroad Company. In 1933, all of the property of Missouri Pacific was placed under the jurisdiction of the Federal courts and the Interstate Commerce Commission for reorganization under section 77 of the Bankruptcy Act. The original reorganization plans of the Commission provided for a reorganization of Missouri Pacific with no value being allotted to the old common stock. During the taxable years 1948 through 1952, petitioner expended $ 541,113.64 in opposing the original reorganization plans…
1Opinion of the Court
Alleghany Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Alleghany Corp. v. Commissioner
Docket Nos. 55210, 56964, 60459
United States Tax Court
28 T.C. 298; 1957 U.S. Tax Ct. LEXIS 203;
April 30, 1957, Filed
Decisions will be entered under Rule 50.
During 1929 and 1930, petitioner acquired more than half of the common stock of the MissouriPacific Railroad Company. In 1933, all of the property of Missouri Pacific was placed under the jurisdiction of the Federal courts and the Interstate Commerce Commission for reorganization under section 77 of the Bankruptcy Act. The…
Also in this document: Dissent.
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
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