Claridge Apartments Co. v. Commissioner
United States Tax Court
1. Neither expenses incident to 77B reorganization assumed by transferee nor nominal stock interest in reorganized company accorded to stockholders of predecessor held to disqualify transaction as a "reorganization" under Revenue Act of 1934, section 112. Helvering v. Southwest Consolidated Corporation, 315 U.S. 194, distinguished.
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1. Neither expenses incident to 77B reorganization assumed by transferee nor nominal stock interest in reorganized company accorded to stockholders of predecessor held to disqualify transaction as a "reorganization" under Revenue Act of 1934, section 112. Helvering v. Southwest Consolidated Corporation, 315 U.S. 194, distinguished. Held, further, on facts exchange of property was solely for petitioner's stock. 2. Provisions of the Chandler Act relating to taxation of income resulting from reduction of indebtedness in reorganizations, held applicable to the entire calendar year 1938, and to…
1Opinion of the Court
Claridge Apartments Company, an Illinois Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Claridge Apartments Co. v. Commissioner
Docket No. 106868
United States Tax Court
1 T.C. 163; 1942 U.S. Tax Ct. LEXIS 26;
December 4, 1942, Promulgated
Decision will be entered under Rule 50.
1. Neither expenses incident to 77B reorganization assumed by transferee nor nominal stock interest in reorganized company accorded to stockholders of predecessor held to disqualify transaction as a "reorganization" under Revenue Act of 1934, section 112. Helvering v. Southwest Consolidated…
Also in this document: Concurrence.
2Cases cited13 opinions
- A. B. Kirschbaum Co. v. WallingSupreme Court of the United States · 1942
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Northern Pacific Railway Co. v. BoydSupreme Court of the United States · 1913
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
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