New York Fruit Auction Corp. v. Commissioner
United States Tax Court
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
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
14 more not listed; retrieve them via the Exa API.