Legal Opinion

Muchnic v. Commissioner

United States Board of Tax Appeals

Decided October 26, 1933No. Docket Nos. 63789, 63790Published

A corporation offered to exchange preferred stock, previously authorized but then unissued, for outstanding common stock. A part of the common stock outstanding was exchanged in accordance with the offer. Held, such exchanges effected a recapitalization of the company constituting a statutory reorganization and are transactions upon which gain or loss is not to be recognized.

1Opinion of the Court

H. E. MUCHNIC, ADMINISTRATOR, ESTATE OF CLIVE HASTINGS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

E. E. HASTINGS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Muchnic v. Commissioner

Docket Nos. 63789, 63790.

United States Board of Tax Appeals

29 B.T.A. 163; 1933 BTA LEXIS 984;

October 26, 1933, Promulgated

A corporation offered to exchange preferred stock, previously authorized but then unissued, for outstanding common stock. A part of the common stock outstanding was exchanged in accordance with the offer. Held, such exchanges effected a recapitalization of the…

2Cases cited6 opinions

  1. Commissioner v. ConnellySupreme Court of the United States · 1949
  2. Burdick v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Cortland Specialty Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  4. First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Fredericks v. CommissionerUnited States Board of Tax Appeals · 1930

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