Hudson v. Commissioner
United States Board of Tax Appeals
1. Stockholders of corporation F agreed with an underwriting firm to exchange all of their stock for all of the preferred shares and 120,000 of the common shares of newly organized corporation S. The shares were all placed in escrow, followed by delivery of the preferred shares and 20,000 of the common shares of corporation S to the stockholders of corporation F. The remaining 100,000 shares of corporation S were delivered to the underwriters for $2,790,000 cash, which was…
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1. Stockholders of corporation F agreed with an underwriting firm to exchange all of their stock for all of the preferred shares and 120,000 of the common shares of newly organized corporation S. The shares were all placed in escrow, followed by delivery of the preferred shares and 20,000 of the common shares of corporation S to the stockholders of corporation F. The remaining 100,000 shares of corporation S were delivered to the underwriters for $2,790,000 cash, which was distributed to the stockholders of corporation F. Held, that a reorganization was effected between the stockholders of…
1Opinion of the Court
HENRY HUDSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hudson v. Commissioner
Docket No. 54774.
United States Board of Tax Appeals
39 B.T.A. 1075; 1939 BTA LEXIS 935;
May 25, 1939, Promulgated
1. Stockholders of corporation F agreed with an underwriting firm to exchange all of their stock for all of the preferred shares and 120,000 of the common shares of newly organized corporation S. The shares were all placed in escrow, followed by delivery of the preferred shares and 20,000 of the common shares of corporation S to the stockholders of corporation F. The remaining 100,000…
2Cases cited17 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Helvering v. RankinSupreme Court of the United States · 1935
- Sinclair Refining Co. v. Jenkins Petroleum Process Co.Supreme Court of the United States · 1933
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
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