Park & Tilford v. Commissioner
United States Board of Tax Appeals
Pursuant to contract dated June 9, 1933, Corporations A and B, on June 30, 1933, transferred certain of their assets to Corporations Y and Z, respectively, wholly owned subsidiaries of Corporation X, in exchange for stock and debentures of X, and immediately distributed the stock and debentures received to their stockholders, Corporations C and D, respectively.
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Pursuant to contract dated June 9, 1933, Corporations A and B, on June 30, 1933, transferred certain of their assets to Corporations Y and Z, respectively, wholly owned subsidiaries of Corporation X, in exchange for stock and debentures of X, and immediately distributed the stock and debentures received to their stockholders, Corporations C and D, respectively. Previously, on June 23 and 24, respectively, A and B had transferred their assets not covered by the contract of June 9 to C in exchange for the stock of C, and immediately after the transfer of such assets by B on June 24 B was in…
1Opinion of the Court
PARK & TILFORD, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Park & Tilford v. Commissioner
Docket Nos. 89181, 89182, 89184-89195, 94024-94069.
United States Board of Tax Appeals
43 B.T.A. 348; 1941 BTA LEXIS 1513;
January 16, 1941, Promulgated
Pursuant to contract dated June 9, 1933, Corporations A and B, on June 30, 1933, transferred certain of their assets to Corporations Y and Z, respectively, wholly owned subsidiaries of Corporation X, in exchange for stock and debentures of X, and immediately distributed the stock and debentures received to their stockholders,…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Groman v. CommissionerSupreme Court of the United States · 1937
- Edwards v. Chile Copper Co.Supreme Court of the United States · 1926
- Helvering v. BashfordSupreme Court of the United States · 1938
- Mellon v. CommissionerUnited States Board of Tax Appeals · 1937
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