Fifth Ave. Bank v. Commissioner
United States Board of Tax Appeals
Petitioner's decedent owned stock in a corporation which exchanged its assets for all the preferred stock in another corporation and a certain amount of common stock in a third corporation, these two kinds of stock being distributed directly to the stockholders of the old corporation, which then dissolved.
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Petitioner's decedent owned stock in a corporation which exchanged its assets for all the preferred stock in another corporation and a certain amount of common stock in a third corporation, these two kinds of stock being distributed directly to the stockholders of the old corporation, which then dissolved. In connection with the transaction a subsidiary of the corporation which issued the common stock agreed to buy all of such stock within 10 days after completion of the exchange. Decedent exercised the option and sold the common stock. Held: (1) The transaction was an exchange of stock for…
1Opinion of the Court
THE FIFTH AVENUE BANK OF NEW YORK, AS EXECUTOR OF THE ESTATE OF FREDERIC D. BELL, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fifth Ave. Bank v. Commissioner
Docket No. 69534.
United States Board of Tax Appeals
31 B.T.A. 945; 1934 BTA LEXIS 1011;
December 26, 1934, Promulgated
Petitioner's decedent owned stock in a corporation which exchanged its assets for all the preferred stock in another corporation and a certain amount of common stock in a third corporation, these two kinds of stock being distributed directly to the stockholders of the old corporation, which then…
2Cases cited8 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Ward v. CommissionerUnited States Board of Tax Appeals · 1934
- First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1930
- Fifth Ave. Bank v. CommissionerUnited States Board of Tax Appeals · 1934
- J. M. Harrison, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
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