Tex-Penn Oil Co. v. Commissioner
United States Board of Tax Appeals
1. Upon the facts developed in these cases it is concluded, (1) that petitioner, Tex-Penn Oil Co., received both cash and stock of the Transcontinental Oil Co. as consideration for its assets, and (2) that part of the cash ostensibly paid individuals for lease interests was in fact consideration for their stock in the Tex-Penn Oil Co. Accordingly, the sole consideration received by Tex-Penn for its assets and by the stockholders for their stock, was not stock or securities…
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1. Upon the facts developed in these cases it is concluded, (1) that petitioner, Tex-Penn Oil Co., received both cash and stock of the Transcontinental Oil Co. as consideration for its assets, and (2) that part of the cash ostensibly paid individuals for lease interests was in fact consideration for their stock in the Tex-Penn Oil Co. Accordingly, the sole consideration received by Tex-Penn for its assets and by the stockholders for their stock, was not stock or securities of Transcontinental, and it is held, that the transaction does not come within those portions of section 202(b) of the…
1Opinion of the Court
TEX-PENN OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
F. B. PARRIOTT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
M. L. BENEDUM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Tex-Penn Oil Co. v. Commissioner
Docket Nos. 11539, 30989, 30990.
United States Board of Tax Appeals
28 B.T.A. 917; 1933 BTA LEXIS 1063;
August 8, 1933, Promulgated
1. Upon the facts developed in these cases it is concluded, (1) that petitioner, Tex-Penn Oil Co., received both cash and stock of the Transcontinental Oil Co. as consideration for its assets, and (2) that…
2Cases cited26 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Corliss v. BowersSupreme Court of the United States · 1930
- The Minnesota Rate CasesSupreme Court of the United States · 1913
- Palmer v. BenderSupreme Court of the United States · 1932
- United States v. PhellisSupreme Court of the United States · 1921
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