Legal Opinion

Warden v. Commissioner

United States Board of Tax Appeals

Decided May 4, 1931No. Docket Nos. 32596, 36756, 38993Published

Where a corporation sells a part of its assets and the amount received therefor is paid directly to two stockholders owning all the stock except a single qualifying share, the transaction is a sale by the corporation and the profit realized, if any, is an element of its gross income.

1Opinion of the Court

FRANK G. WARDEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SEVERS HOTEL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

W. B. NATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Warden v. Commissioner

Docket Nos. 32596, 36756, 38993.

United States Board of Tax Appeals

23 B.T.A. 24; 1931 BTA LEXIS 1937;

May 4, 1931, Promulgated

Where a corporation sells a part of its assets and the amount received therefor is paid directly to two stockholders owning all the stock except a single qualifying share, the transaction is a sale by the corporation and…

2Cases cited1 opinion

  1. Warden v. CommissionerUnited States Board of Tax Appeals · 1931

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