Bamberger v. Commissioner
United States Board of Tax Appeals
1. STOCK DISTRIBUTION - BASIS OF COST TO OLD AND NEW SHARES. Where petitioners were the shareholders of B Company, and B Company caused A Company and N Company and C Company to be organized and transferred a good part of its assets, consisting of common stocks and securities of other corporations, to A, N, and C Companies, for which said companies issued all their shares to B Company, which shares were in turn distributed by B Company to petitioners as stockholders of B…
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1. STOCK DISTRIBUTION - BASIS OF COST TO OLD AND NEW SHARES. Where petitioners were the shareholders of B Company, and B Company caused A Company and N Company and C Company to be organized and transferred a good part of its assets, consisting of common stocks and securities of other corporations, to A, N, and C Companies, for which said companies issued all their shares to B Company, which shares were in turn distributed by B Company to petitioners as stockholders of B Company, and where A Company and N Company soon thereafter liquidated by distributing all their assets, consisting of shares…
1Opinion of the Court
*789OPINION.
Black:
It is conceded by both parties that the transactions occurring in June 1929, by which three subsidiary corporations were organized and to which Bamberger Investment and Exploration Company transferred much of its valuable stocks and securities, *790receiving in consideration therefor all the capital stock of the subsidiary corporations and in turn distributing said shares of stock to its own stockholders as a part of the plans of reorganization, were nontaxable transactions under the provisions of the Revenue Act of 1928.
The stock of these three subsidiary corporations which was…
2Cases cited4 opinions
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Untermyer v. AndersonSupreme Court of the United States · 1928
- Shwab v. DoyleSupreme Court of the United States · 1922
- Coolidge v. LongSupreme Court of the United States · 1931
3Cited by5 opinions
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- Bamberger v. CommissionerUnited States Board of Tax Appeals · 1933
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