Bedford v. Commissioner
United States Tax Court
Petitioner was an income beneficiary of certain trusts under which the trustee was required to pay the income "as frequently as may be convenient." The corpora of the trusts consisted in part of cumulative preferred stock of corporation A which had been guaranteed by corporation B. Both corporations were reorganized under section 77 (B) of the Federal Bankruptcy Act.
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Petitioner was an income beneficiary of certain trusts under which the trustee was required to pay the income "as frequently as may be convenient." The corpora of the trusts consisted in part of cumulative preferred stock of corporation A which had been guaranteed by corporation B. Both corporations were reorganized under section 77 (B) of the Federal Bankruptcy Act. Under the plan of reorganization the preferred stockholders of corporation A received new preferred stock of that corporation in lieu of the old preferred stock. They also received new preferred stock of corporation B in…
1Opinion of the Court
OPINION.
HaRRon, Judge:
The first question for determination is whether the new preferred stock of the Terminal Co. was received by the trustee during the taxable year as part of a nontaxable reorganization under section 112 (b) (3) of the Internal Revenue Code.1
Although the trustee was not a stockholder of the Terminal Co., petitioner contends that the stock of that company was received under a single plan for the reorganization of both the Terminal Co. and the Buildings Co. and that the Terminal Co. was a “party to the reorganization” of the Buildings Co. He argues that the Terminal Co. must…
2Cases cited6 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Morrison v. CaliforniaSupreme Court of the United States · 1934
- Hort v. CommissionerSupreme Court of the United States · 1941
- Groman v. CommissionerSupreme Court of the United States · 1937
- Helvering v. BashfordSupreme Court of the United States · 1938
1 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Earle v. CommissionerUnited States Tax Court · 1945
- Bedford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Estate of Bruchmann, etc. v. CommissionerUnited States Tax Court · 1969
- Bedford v. CommissionerUnited States Tax Court · 1943
- Bedford v. CommissionerUnited States Tax Court · 1944
6 more not listed; retrieve them via the Exa API.