Berckmans v. Commissioner
United States Tax Court
Petitioner subscribed for shares of new common stock of a corporation and paid $1 per share, the par value. At the time he purchased the stock, there was a plan whereby the corporation, which then had no assets, would purchase the assets of 2 corporations which had been engaged actively in the conduct of their respective businesses, provided the required capital could be obtained through obtaining loans and a large block of the new stock could be offered to the public…
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Petitioner subscribed for shares of new common stock of a corporation and paid $1 per share, the par value. At the time he purchased the stock, there was a plan whereby the corporation, which then had no assets, would purchase the assets of 2 corporations which had been engaged actively in the conduct of their respective businesses, provided the required capital could be obtained through obtaining loans and a large block of the new stock could be offered to the public through underwriting concerns and sold. As of the date of petitioner's purchase of the stock, there remained several…
1Opinion of the Court
Bruce Berckmans and Hildegarde Berckmans v. Commissioner.
Berckmans v. Commissioner
Docket No. 73967.
United States Tax Court
T.C. Memo 1961-100; 1961 Tax Ct. Memo LEXIS 255; 20 T.C.M. (CCH) 458; T.C.M. (RIA) 61100;
March 31, 1961
Petitioner subscribed for shares of new common stock of a corporation and paid $1 per share, the par value. At the time he purchased the stock, there was a plan whereby the corporation, which then had no assets, would purchase the assets of 2 corporations which had been engaged actively in the conduct of their respective businesses, provided the required capital could be…
2Cases cited8 opinions
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Fred M. Archer and Evie B. Archer v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Helvering v. Safe Deposit & Trust Co. of BaltimoreCourt of Appeals for the Fourth Circuit · 1938
- Helvering v. MaytagCourt of Appeals for the Eighth Circuit · 1942
- Fox River Paper Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1948
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