Fred H. Lenway & Co. v. Commissioner
United States Tax Court
Petitioner was a party to a transaction involving the revamping of the capital structure of X corporation, in which petitioner held a 55-percent stock interest.
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Petitioner was a party to a transaction involving the revamping of the capital structure of X corporation, in which petitioner held a 55-percent stock interest. As part of that transaction, petitioner contributed some of its shares to the capital of X. It also warranted the net worth of X as of a given date to a third party, which made a substantial investment in X. Petitioner's obligation under the warranty could be satisfied by transferring additional amounts of its shares to X. Petitioner gave up all of its remaining shares of X in satisfaction of the warranty. Held, petitioner's loss in…
1Opinion of the Court
Fred H. Lenway & Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Fred H. Lenway & Co. v. Commissioner
Docket No. 6370-74
United States Tax Court
69 T.C. 620; 1978 U.S. Tax Ct. LEXIS 187;
January 30, 1978, Filed
Decision will be entered for the respondent.
Petitioner was a party to a transaction involving the revamping of the capital structure of X corporation, in which petitioner held a 55-percent stock interest. As part of that transaction, petitioner contributed some of its shares to the capital of X. It also warranted the net worth of X as of a given date to a third…
Also in this document: Dissent.
2Cases cited42 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Crane v. CommissionerSupreme Court of the United States · 1947
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- United States v. DavisSupreme Court of the United States · 1962
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