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