Whitney Realty Co. v. Commissioner
United States Board of Tax Appeals
Prior to its dissolution a corporation transferred its assets to one of its officers, who, by declaration of trust, agreed to hold the assets in trust, relieve them from liability by paying the corporate debts, and distribute the proceeds among the stockholders.
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Prior to its dissolution a corporation transferred its assets to one of its officers, who, by declaration of trust, agreed to hold the assets in trust, relieve them from liability by paying the corporate debts, and distribute the proceeds among the stockholders. Held, that there was no distribution in kind of the corporate assets upon an exchange by the stockholders of shares of stock for trust certificates, nor was there a transaction whereby gain or loss resulted to the stockholders from the exchange.
1Opinion of the Court
WHITNEY REALTY COMPANY, LTD., PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Whitney Realty Co. v. Commissioner
Docket Nos. 48192, 51719-51724, 57757-57759.
United States Board of Tax Appeals
29 B.T.A. 453; 1933 BTA LEXIS 938;
November 28, 1933, Promulgated
Prior to its dissolution a corporation transferred its assets to one of its officers, who, by declaration of trust, agreed to hold the assets in trust, relieve them from liability by paying the corporate debts, and distribute the proceeds among the stockholders. Held, that there was no distribution in kind of the corporate…
2Cases cited1 opinion
- Whitney Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1933