Graham v. Commissioner
United States Board of Tax Appeals
1. Corporation A, desiring to liquidate, transferred approximately 95 percent of its assets to B for cash and the debentures of X, which owned all of B. The debentures matured in about six and one-half years, but were called the following year.
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1. Corporation A, desiring to liquidate, transferred approximately 95 percent of its assets to B for cash and the debentures of X, which owned all of B. The debentures matured in about six and one-half years, but were called the following year. Held, not a reorganization under section 112(i)(1)(A) of the Revenue Act of 1932, there being no plan of reorganization and no such continuing interest in B as required by the statute. 2. Corporation A transferred the remaining 5 percent of its assets to C, a corporation created to liquidate the assets, for all of C's stock. Held, not a reorganization…
1Opinion of the Court
GEORGE D. GRAHAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
NEVA B. GRAHAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Graham v. Commissioner
Docket Nos. 87570, 87571.
United States Board of Tax Appeals
37 B.T.A. 623; 1938 BTA LEXIS 1009;
April 8, 1938, Promulgated
1. Corporation A, desiring to liquidate, transferred approximately 95 percent of its assets to B for cash and the debentures of X, which owned all of B. The debentures matured in about six and one-half years, but were called the following year. Held, not a reorganization under section 112(i)(1)(A) of…
2Cases cited7 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Groman v. CommissionerSupreme Court of the United States · 1937
- Helvering v. BashfordSupreme Court of the United States · 1938
- Mellon v. CommissionerUnited States Board of Tax Appeals · 1937
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