Commissioner of Internal Revenue v. Sansome

L. HAND) Circuit Judge.

Sansome, the taxpayer, on January 1, 1921, bought some shares of stock, having $109 par value, in a New Jersey company, which on April 1,1921, sold out all its assets to another company of the same state. The new company assumed all existing liabilities, and issued its shares to the shareholders of the old, without change in the proportion of their holdings, though the number of new shares was increased five times, and they were without par value. The new charter .differed only in that the company could manufacture other products besides silk, to which the charter of…