Redfield v. Commissioner
United States Board of Tax Appeals
1. On the facts, held, that petitioners sustained losses in 1932 representing their investments in the capital stock of corporation A by reason of such stock becoming worthless in that year. 2. In 1930 corporation A acquired all the assets of corporation B in exchange for shares of A's capital stock, which stock was thereupon distributed pro rata among the stockholders of B, pursuant to a plan of reorganization.
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1. On the facts, held, that petitioners sustained losses in 1932 representing their investments in the capital stock of corporation A by reason of such stock becoming worthless in that year. 2. In 1930 corporation A acquired all the assets of corporation B in exchange for shares of A's capital stock, which stock was thereupon distributed pro rata among the stockholders of B, pursuant to a plan of reorganization. Held, said transaction constituted a reorganization within the meaning of section 112(i)(1)(A), Revenue Act of 1928, whether or not corporation B was thereafter dissolved, and the…
1Opinion of the Court
*970OPINION.
Hill:
Issue (1). — Each of the petitioners herein deducted in his income tax return for 1932 the cost of his stock in the Connecticut Corporation on the theory that the stock of the Process Corporation became worthless in 1932, and that the transaction by which the Process Corporation acquired all the assets of the Connecticut Corporation for shares of stock in 1930 was a reorganization in connection with which no profit or loss was recognizable for tax purposes. Hence, *971the measure of the loss was the cost of the stock in the Connecticut Corporation.
Respondent disallowed the claimed…
2Cases cited3 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
3Cited by13 opinions
- King Enterprises, Inc. v. The United StatesUnited States Court of Claims · 1969
- Herder v. HelveringCourt of Appeals for the D.C. Circuit · 1939
- Mills v. CommissionerUnited States Tax Court · 1962
- Cammack v. United StatesCourt of Appeals for the Eighth Circuit · 1940
- Wilson v. CommissionerUnited States Tax Court · 1943
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