White v. Commissioner
United States Board of Tax Appeals
1. Where a corporation, by issuing its own stock and paying cash, acquires a majority of the voting stock of another but less than a majority of the nonvoting stock, the transaction is not a reorganization under the Revenue Act of 1928, and the stockholders do not come within the provisions of that act limiting the recognition of gain or loss. 2. The evidence fails to establish a deposit by the purchasing corporation to complete the purchase prior to November 26, 1929, any…
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1. Where a corporation, by issuing its own stock and paying cash, acquires a majority of the voting stock of another but less than a majority of the nonvoting stock, the transaction is not a reorganization under the Revenue Act of 1928, and the stockholders do not come within the provisions of that act limiting the recognition of gain or loss. 2. The evidence fails to establish a deposit by the purchasing corporation to complete the purchase prior to November 26, 1929, any obligation to make a deposit, or any right in the stockholders to demand payment before that date. Held, there was no…
1Opinion of the Court
THOMAS W. WHITE, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
White v. Commissioner
Docket Nos. 63228, 63234-63238, 63451, 64127, 66886, 66887, 66902, 67832.
United States Board of Tax Appeals
29 B.T.A. 1272; 1934 BTA LEXIS 1408;
February 27, 1934, Promulgated
1. Where a corporation, by issuing its own stock and paying cash, acquires a majority of the voting stock of another but less than a majority of the nonvoting stock, the transaction is not a reorganization under the Revenue Act of 1928, and the stockholders do not come within the provisions of that act limiting the…
2Cases cited2 opinions
- Powel v. CommissionerUnited States Board of Tax Appeals · 1932
- White v. CommissionerUnited States Board of Tax Appeals · 1934