Legal Opinion

Sprague-Sells Corp. v. Commissioner

United States Board of Tax Appeals

Decided July 12, 1934No. Docket Nos. 42006, 42434Published

Corporation A issued a portion of its stock for all of the shares of stock and all of the assets of corporation B. Corporation B was not dissolved although from the time it parted with its assets; it had neither income nor expenses. Held, that the net losses of corporation B may not be deducted from the gross income of corporation A.

1Opinion of the Court

SPRAGUE-SELLS CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Sprague-Sells Corp. v. Commissioner

Docket Nos. 42006, 42434.

United States Board of Tax Appeals

30 B.T.A. 1165; 1934 BTA LEXIS 1213;

July 12, 1934, Promulgated

Corporation A issued a portion of its stock for all of the shares of stock and all of the assets of corporation B. Corporation B was not dissolved although from the time it parted with its assets; it had neither income nor expenses. Held, that the net losses of corporation B may not be deducted from the gross income of corporation A.

Harold W. Norman,…

2Cases cited1 opinion

  1. Sprague-Sells Corp. v. CommissionerUnited States Board of Tax Appeals · 1934

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