Utilities & Industries Corp. v. Commissioner
United States Tax Court
1. Basis for Gain or Loss -- Acquisition by Reorganization or Purchase. -- Held, petitioner South Bay's acquisitions of the properties of two corporations in 1925 were in connection with separate reorganizations under section 203(h) of the Revenue Act of 1924, and pursuant to section 113(a)(7), I.R.C. 1939, petitioner's basis is the same as it would be in the hands of each respective transferor and, further, that petitioner failed to establish each transferor's basis and its…
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1. Basis for Gain or Loss -- Acquisition by Reorganization or Purchase. -- Held, petitioner South Bay's acquisitions of the properties of two corporations in 1925 were in connection with separate reorganizations under section 203(h) of the Revenue Act of 1924, and pursuant to section 113(a)(7), I.R.C. 1939, petitioner's basis is the same as it would be in the hands of each respective transferor and, further, that petitioner failed to establish each transferor's basis and its own adjusted basis at date of sale as required by section 113(b), I.R.C. 1939. Held, further, that petitioner's…
1Opinion of the Court
Utilities & Industries Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent; The South Bay Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Utilities & Industries Corp. v. Commissioner
Docket Nos. 88306, 88307
United States Tax Court
41 T.C. 888; 1964 U.S. Tax Ct. LEXIS 127;
March 27, 1964, Filed
Decision in each docket number herein will be entered under Rule 50.
1. Basis for Gain or Loss -- Acquisition by Reorganization or Purchase. -- Held, petitioner South Bay's acquisitions of the properties of two corporations in 1925 were in connection with separate…
2Cases cited13 opinions
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Magruder v. SuppleeSupreme Court of the United States · 1942
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Shea v. CommissionerUnited States Tax Court · 1961
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