Evans v. Commissioner
United States Board of Tax Appeals
The Union Co. in December 1928 entered into a contract with the stockholders of the Miller Co. to purchase from them all of the stock of the latter company in exchange for cash and the stock of the purchaser, the latter to be delivered as soon as a permit could be secured from the Corporation Commissioner of California. Thirty-nine percent was to be paid in cash on the signing of the contract and the remaining cash was to be paid in 1929. The cash payment for 1928 was made.
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The Union Co. in December 1928 entered into a contract with the stockholders of the Miller Co. to purchase from them all of the stock of the latter company in exchange for cash and the stock of the purchaser, the latter to be delivered as soon as a permit could be secured from the Corporation Commissioner of California. Thirty-nine percent was to be paid in cash on the signing of the contract and the remaining cash was to be paid in 1929. The cash payment for 1928 was made. The Union Co. secured a permit to issue its stock in January 1929 and the stock was then delivered and the remaining…
1Opinion of the Court
A. T. EVANS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
M. RUIZ, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
W. E. STEEGE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Evans v. Commissioner
Docket Nos. 64397, 67097, 67098.
United States Board of Tax Appeals
30 B.T.A. 746; 1934 BTA LEXIS 1273;
May 17, 1934, Promulgated
The Union Co. in December 1928 entered into a contract with the stockholders of the Miller Co. to purchase from them all of the stock of the latter company in exchange for cash and the stock of the purchaser, the latter to be delivered…
2Cases cited2 opinions
- National Iron Works v. CommissionerUnited States Board of Tax Appeals · 1931
- Evans v. CommissionerUnited States Board of Tax Appeals · 1934