Adwood Corp. v. Commissioner
United States Tax Court
1. Basis -- Reorganization -- Section 112 (g) (1) (C). -- Where the original mortgagor (lessee) had lost its interest in the property by cancellation of its lease before the mortgagees started foreclosure, there was no transfer from it to the purchaser at the foreclosure sale within the meaning of section 112 (g) (1) (C) and the petitioner does not take the mortgagor's basis.
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1. Basis -- Reorganization -- Section 112 (g) (1) (C). -- Where the original mortgagor (lessee) had lost its interest in the property by cancellation of its lease before the mortgagees started foreclosure, there was no transfer from it to the purchaser at the foreclosure sale within the meaning of section 112 (g) (1) (C) and the petitioner does not take the mortgagor's basis. Bondholders Committee, Marlborough Investment Company First Mortgage Bonds v. Commissioner, 315 U.S. 189, followed. 2. Basis -- Sections 112 (b) (5) and 113 (a) (8). -- Section 112 (b) (5) does not apply where the…
1Opinion of the Court
Adwood Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Adwood Corp. v. Commissioner
Docket No. 19202
United States Tax Court
15 T.C. 148; 1950 U.S. Tax Ct. LEXIS 108;
August 25, 1950, Promulgated
Decision will be entered for the respondent.
1. Basis -- Reorganization -- Section 112 (g) (1) (C). -- Where the original mortgagor (lessee) had lost its interest in the property by cancellation of its lease before the mortgagees started foreclosure, there was no transfer from it to the purchaser at the foreclosure sale within the meaning of section 112 (g) (1) (C) and the…
2Cases cited4 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Bondholders Committee v. CommissionerSupreme Court of the United States · 1942
- Adwood Corp. v. CommissionerUnited States Tax Court · 1950