Harwell v. Commissioner

PHILLIPS, Chief Judge.

This is a petition to review a decision of the Tax Court. On September 30, 1937, E. P. Harwell, who owned all of the outstanding stock of the Trinity Farm Securities Company, a corporation, exchanged all of such stock for the assets of the corporation. A part of the assets thus acquired was approximately 4500 acres of land situate in Dallas County Levee Improvement District No. 5.1 On the date of the exchange, the accrued and unpaid taxes, interest, and penalties assessed against the land amounted to $307,900.73.

Prior to and during the year 1940, the Improvement District…