Niagara Share Corp. v. Commissioner
United States Board of Tax Appeals
1. A loss sustained in 1929 by a corporation through the liquidation, prior to dissolution, of an affiliated corporation of which it owns all the shares is not deductible on consolidated return, Ilfeld Co. v. Hernandez,292 U.S. 62. 2. The exchange by a corporation of shares held by it in an unaffiliated corporation for some of its own shares owned by the other corporation, the value of its own shares received being less than the cost of the shares given up, supports a…
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1. A loss sustained in 1929 by a corporation through the liquidation, prior to dissolution, of an affiliated corporation of which it owns all the shares is not deductible on consolidated return, Ilfeld Co. v. Hernandez,292 U.S. 62. 2. The exchange by a corporation of shares held by it in an unaffiliated corporation for some of its own shares owned by the other corporation, the value of its own shares received being less than the cost of the shares given up, supports a deduction for loss.
1Opinion of the Court
NIAGARA SHARE CORPORATION (OF DELAWARE), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
NIAGARA SHARE CORPORATION (OF NEW YORK), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MORTGAGE SECURITY CORPORATION OF NEW JERSEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
KNICKERBOCKER FUNDING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MORSECO REALTY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Niagara Share Corp. v. Commissioner
Docket Nos. 66922-66926.
United States Board of Tax Appeals
30 B.T.A. 668;…
2Cases cited2 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Niagara Share Corp. v. CommissionerUnited States Board of Tax Appeals · 1934