Legal Opinion

R. J. Reynolds Tobacco Co. v. Commissioner

United States Board of Tax Appeals

Decided April 27, 1937No. Docket No. 71901Published

Over a period of several years, in pursuance of its policy of broadening its stockholding base, protecting its stock and business and to support the market, petitioner corporation bought shares of its own stock for cash on the open market and later sold certain of the shares so acquired. The stock was not retired but was held as treasury stock and carried in its investment account. During the taxable year 1929 petitioner so bought 574,000 shares.

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Over a period of several years, in pursuance of its policy of broadening its stockholding base, protecting its stock and business and to support the market, petitioner corporation bought shares of its own stock for cash on the open market and later sold certain of the shares so acquired. The stock was not retired but was held as treasury stock and carried in its investment account. During the taxable year 1929 petitioner so bought 574,000 shares. Also during the taxable year petitioner sold 194,000 shares of its own stock acquired during 1929, and 15,000 shares previously acquired. These…

1Opinion of the Court

R. J. REYNOLDS TOBACCO COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

R. J. Reynolds Tobacco Co. v. Commissioner

Docket No. 71901.

United States Board of Tax Appeals

35 B.T.A. 949; 1937 BTA LEXIS 808;

April 27, 1937, Promulgated

Over a period of several years, in pursuance of its policy of broadening its stockholding base, protecting its stock and business and to support the market, petitioner corporation bought shares of its own stock for cash on the open market and later sold certain of the shares so acquired. The stock was not retired but was held as treasury stock and…

2Cases cited51 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
  3. Brewster v. GageSupreme Court of the United States · 1930
  4. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  5. Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936

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