Copland v. Department of Taxation

In order to better understand the questions here presented we deem it necessary to first examine the 1947 transactions. Since the purchasers of the 75 percent interest in the old corporation paid $1,050,000, that was their tax basis in the stock acquired. None of these stockholders were residents of Wisconsin, and the ensuing transactions were conducted with little, if any, regard for Wisconsin law. Apparently, the plan was to write up the corporation’s assets to the level reflected by the price paid therefor by the Thomson group. On this basis the total net assets were valued at $1,400,000.…