Legal Opinion

New York Fruit Auction Corp. v. Commissioner

United States Tax Court

Decided September 28, 1982No. Docket No. 3734-80Published

Corporation A acquired all the stock of corporation B. Corporation A was then merged into corporation B. Held, neither sec. 334(b)(2), I.R.C. 1954, nor the "integrated transaction" doctrine applies to permit a step-up in basis of the assets of corporation B.

1Opinion of the Court

New York Fruit Auction Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

New York Fruit Auction Corp. v. Commissioner

Docket No. 3734-80

United States Tax Court

79 T.C. 564; 1982 U.S. Tax Ct. LEXIS 34; 79 T.C. No. 36;

September 28, 1982, Filed

Decision will be entered for the respondent.

Corporation A acquired all the stock of corporation B. Corporation A was then merged into corporation B. Held, neither sec. 334(b)(2), I.R.C. 1954, nor the "integrated transaction" doctrine applies to permit a step-up in basis of the assets of corporation B.

Michael A. Varet, for the petitioner.

V…

2Cases cited19 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  3. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
  4. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  5. Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947

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