Gabriel Co. v. Commissioner
United States Tax Court
In 1925 petitioner entered into a transaction whereby it acquired the business and assets of a sole proprietorship for 1,000 shares, or one-half, of its class B voting stock and cash in the amount of $ 4,358,705.70, which cash was obtained from an underwriting concern to which petitioner sold 197,950 shares of its class A nonvoting stock and 950 shares of its class B stock.
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In 1925 petitioner entered into a transaction whereby it acquired the business and assets of a sole proprietorship for 1,000 shares, or one-half, of its class B voting stock and cash in the amount of $ 4,358,705.70, which cash was obtained from an underwriting concern to which petitioner sold 197,950 shares of its class A nonvoting stock and 950 shares of its class B stock. Held, that the petitioner, in computing the amount of its equity invested capital under section 718 (a) of the Internal Revenue Code, is limited to the amount of the cash, plus the value of the 1,000 shares of its class B…
1Opinion of the Court
The Gabriel Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Gabriel Co. v. Commissioner
Docket No. 17684
United States Tax Court
13 T.C. 559; 1949 U.S. Tax Ct. LEXIS 63;
October 17, 1949, Promulgated
Decision will be entered under Rule 50.
In 1925 petitioner entered into a transaction whereby it acquired the business and assets of a sole proprietorship for 1,000 shares, or one-half, of its class B voting stock and cash in the amount of $ 4,358,705.70, which cash was obtained from an underwriting concern to which petitioner sold 197,950 shares of its class A nonvoting stock and…
2Cases cited3 opinions
- Palomar Laundry v. CommissionerUnited States Tax Court · 1946
- American Business Credit Corp. v. CommissionerUnited States Tax Court · 1947
- Gabriel Co. v. CommissionerUnited States Tax Court · 1949