Hall v. Commissioner
United States Board of Tax Appeals
EXCHANGE OF PROPERTY FOR STOCK - RECOGNITION OF GAIN. - Petitioner subscribed for all the common stock of a newly organized corporation and offered to exchange stock of another corporation, not then organized, as part payment and the balance in cash, conditional upon the corporation purchasing from him certain securities for an amount in excess of the cash owing on his subscription.
Read the full summary
EXCHANGE OF PROPERTY FOR STOCK - RECOGNITION OF GAIN. - Petitioner subscribed for all the common stock of a newly organized corporation and offered to exchange stock of another corporation, not then organized, as part payment and the balance in cash, conditional upon the corporation purchasing from him certain securities for an amount in excess of the cash owing on his subscription. The offer was accepted by resolution of the directors on August 2, 1928, but the exchange was not then actually completed. At that time persons other than petitioner had subscribed for a substantial portion of the…
1Opinion of the Court
CHARLES HALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hall v. Commissioner
Docket No. 59299.
United States Board of Tax Appeals
31 B.T.A. 125; 1934 BTA LEXIS 1159;
August 29, 1934, Promulgated
EXCHANGE OF PROPERTY FOR STOCK - RECOGNITION OF GAIN. - Petitioner subscribed for all the common stock of a newly organized corporation and offered to exchange stock of another corporation, not then organized, as part payment and the balance in cash, conditional upon the corporation purchasing from him certain securities for an amount in excess of the cash owing on his subscription. The…
2Cases cited1 opinion
- Hall v. CommissionerUnited States Board of Tax Appeals · 1934