Pennsylvania Water & Power Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner acquired all the assets of its wholly owned subsidiary in consideration of the delivery to it of all the subsidiary's capital stock and the assumption by it of all of the subsidiary's indebtedness. This was done under a Pennsylvania statute sometimes referred to as permitting a "short form of merger."
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1. Petitioner acquired all the assets of its wholly owned subsidiary in consideration of the delivery to it of all the subsidiary's capital stock and the assumption by it of all of the subsidiary's indebtedness. This was done under a Pennsylvania statute sometimes referred to as permitting a "short form of merger." Statute examined and held acquisition by petitioner of the assets of its subsidiary under the statute was a purchase and not a merger. 2. Petitioner retired bonds issued by its former subsidiary and deducted from its gross income, (a) the unamortized discount and expense incurred…
1Opinion of the Court
PENNSYLVANIA WATER & POWER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Pennsylvania Water & Power Co. v. Commissioner
Docket No. 56720.
United States Board of Tax Appeals
36 B.T.A. 467; 1937 BTA LEXIS 707;
August 24, 1937, Promulgated
1. Petitioner acquired all the assets of its wholly owned subsidiary in consideration of the delivery to it of all the subsidiary's capital stock and the assumption by it of all of the subsidiary's indebtedness. This was done under a Pennsylvania statute sometimes referred to as permitting a "short form of merger." Statute examined and held…
2Cases cited13 opinions
- Buist's EstateSupreme Court of Pennsylvania · 1929
- Daily's EstateSupreme Court of Pennsylvania · 1936
- Merwine v. Mt. Pocono Light & Improvement Co.Supreme Court of Pennsylvania · 1931
- York Haven W. & P. Co. v. Public Service CommissionSupreme Court of Pennsylvania · 1926
- Greensburg Borough v. Westmoreland Water Co.Supreme Court of Pennsylvania · 1913
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