Manhattan General Equipment Co. v. Commissioner
United States Board of Tax Appeals
1. A corporation acquired a contract from an individual in an exchange upon which no gain or loss was recognized under the Revenue Act of 1921, and, under the Revenue Act of 1926, the basis for determining gain or loss to the corporation was the same as it would be in the hands of the transferor.
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1. A corporation acquired a contract from an individual in an exchange upon which no gain or loss was recognized under the Revenue Act of 1921, and, under the Revenue Act of 1926, the basis for determining gain or loss to the corporation was the same as it would be in the hands of the transferor. Held, in determining gain or loss resulting from cancellation of the contract prior to the end of its term, the basis should be reduced, not only by the deductions for exhaustion of the contract allowable to the corporation, but also by those allowable to the transferor. 2. Where a stockholder…
1Opinion of the Court
MANHATTAN GENERAL EQUIPMENT COMPANY ET ALI 1, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Manhattan General Equipment Co. v. Commissioner
Docket Nos. 51345-51361, 51363-51370, 51372-51380.
United States Board of Tax Appeals
29 B.T.A. 395; 1933 BTA LEXIS 946;
November 23, 1933, Promulgated
1. A corporation acquired a contract from an individual in an exchange upon which no gain or loss was recognized under the Revenue Act of 1921, and, under the Revenue Act of 1926, the basis for determining gain or loss to the corporation was the same as it would be in the hands of the transferor.…
2Cases cited9 opinions
- United States v. LudeySupreme Court of the United States · 1927
- United States v. FlannerySupreme Court of the United States · 1925
- Even Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Graves, Cox & Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Elliott-Granite Linen Corp. v. CommissionerUnited States Board of Tax Appeals · 1932
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