Whitney v. Commissioner
United States Tax Court
In the taxable year 1940, petitioners were members of the New York partnership of J. P. Morgan & Co. On March 29, 1940, under the Banking Law of New York, they organized a trust company in the name of "J. P. Morgan & Co. Incorporated." They acquired more than 72 per cent of its outstanding stock. On March 30, 1940, by bill of sale and agreement, the partnership transferred certain of its assets to the trust company.
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In the taxable year 1940, petitioners were members of the New York partnership of J. P. Morgan & Co. On March 29, 1940, under the Banking Law of New York, they organized a trust company in the name of "J. P. Morgan & Co. Incorporated." They acquired more than 72 per cent of its outstanding stock. On March 30, 1940, by bill of sale and agreement, the partnership transferred certain of its assets to the trust company. The latter assumed all the liabilities of the partnership and paid to it in cash the difference between the fair market value of the assets transferred and the liabilities…
1Opinion of the Court
George Whitney, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent
Whitney v. Commissioner
Docket Nos. 6514, 6515, 6516, 6517, 6518, 6519, 6520, 6521, 6522, 6523, 6524, 6525, 6547
United States Tax Court
8 T.C. 1019; 1947 U.S. Tax Ct. LEXIS 201;
May 14, 1947, Promulgated
Decisions will be entered under Rule 50.
In the taxable year 1940, petitioners were members of the New York partnership of J. P. Morgan & Co. On March 29, 1940, under the Banking Law of New York, they organized a trust company in the name of "J. P. Morgan & Co. Incorporated." They acquired more than 72 per cent of…
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