Ramapo, Inc. v. Commissioner of Internal Revenue

SWAN, Circuit Judge.

The taxpayer is a corporation which keeps its books and makes its income tax returns on a cash receipts and disbursements basis. During the year 1929 it was a stockholder of the American Superpower Corporation (hereafter for brevity referred to as “Superpower”). By resolutions adopted in January, May, and June, 1929, Superpower gave its stockholders rights to purchase from it at stated prices shares of common stock of the United Corporation and the .Commonwealth & Southern Corporation. Some of the rights so received by the taxpayer it exercised; others it sold. It also…