Claridge Apartments Co. v. Commissioner

The issues arise out of deficiency assessments made in respect to petitioner’s federal income and excess profits taxes for the years 1935 to 1938 inclusive. They involve the applicability of § 270 of the Bankruptcy Act, as amended, 1 so as to require reduction of depreciation allowances claimed.

The transactions arose in connection with a reorganization proceeding under § 77B, 48 Stat. 912. They consisted essentially of petitioner’s acquisition of all the assets of the insolvent debtor corporation, by an exchange of its capital stock without par value for the latter’s bonds then outstanding.…