Cardinal Corp. v. Commissioner

OPINION

Issue 1. Whether $1¡02,521¡..71 Received in the Year 1958 is Gross Income to Petitioner or is it Money Received in Exchcmge for Stock of Petitioner TJnder Section 1082

The first issue to be considered is whether petitioner must include in gross income for 1958 the $402,524.71 received from preferred shareholders and their assignees.

Section 1032 of the Internal Bevenue Code of 1954 provides that no gain or loss shall be recognized to a corporation on the receipt of money or other property in exchange for stock (including treasury stock) of such corporation. Section 1032 had no…