Burlington Gazette Co. v. Commissioner
United States Board of Tax Appeals
DEPRECIATION BASIS. - In 1921 petitioner took over certain assets for which it issued its stock to the transferors in substantially the same proportions as their interests in the assets had been prior thereto.
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DEPRECIATION BASIS. - In 1921 petitioner took over certain assets for which it issued its stock to the transferors in substantially the same proportions as their interests in the assets had been prior thereto. No gain or loss was recognized to the transferors, pursuant to section 202(c)(3) of the Revenue Act of 1921 and section 203(b)(4) of the Revenue Acts of 1924 and 1926. Held that for depreciation of the said assets during 1924 and 1925, the petitioner's depreciation basis is the same as the transferors' basis would have been had the property remained in their hands, section 204(c) and…
1Opinion of the Court
*157OPINION.
Teussell :
There is no controversy as to the facts in this proceeding, as hereinbefore stated. The parties hereto are also in accord as to the fact that, for income-tax purposes, no gain or loss to the transferors was recognized upon the transfer of the assets in question to the petitioner in 1921 for its stock, pursuant to sections 202 (c) (3) of the Revenue Act of 1921 and 203 (b) (4) of the Revenue Acts of 1924 and 1926, which provide that no gain or loss shall be recognized if property is transferred to a corporation by two or more persons in exchange for stock in such corporation…
2Cited by7 opinions
- National Weeklies v. Com'r of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
- United States v. The Albertson Company, a CorporationCourt of Appeals for the Ninth Circuit · 1955
- DURAND-MCNEIL-HORNER CO. v. COMMISSIONERUnited States Board of Tax Appeals · 1934
- Burlington Gazette Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Durand-McNeil-Horner Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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