Legal Opinion

Trinity Corp. v. Commissioner

United States Board of Tax Appeals

Decided August 12, 1941No. Docket No. 103957Published

1. Article 22(a)(16) of Regulations 94, promulgated under the 1936 Act, continuing the administrative interpretation announced in 1934 by T.D. 4430, relating to gain or loss to a corporation in dealings in its own capital stock, is applicable to a transaction made in 1937. 2. The fair market value of shares of its own stock received by petitioner in an exchange of property determined for the purpose of computing gain or loss.

1Opinion of the Court

TRINITY CORPORATION (FORMERLY TRINITY LIFE BUILDING CORP.), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Trinity Corp. v. Commissioner

Docket No. 103957.

United States Board of Tax Appeals

44 B.T.A. 1219; 1941 BTA LEXIS 1210;

August 12, 1941, Promulgated

1. Article 22(a)(16) of Regulations 94, promulgated under the 1936 Act, continuing the administrative interpretation announced in 1934 by T.D. 4430, relating to gain or loss to a corporation in dealings in its own capital stock, is applicable to a transaction made in 1937.

2. The fair market value of shares of its own stock received…

2Cases cited10 opinions

  1. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  2. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  3. Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
  4. Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
  5. Helvering v. ReynoldsSupreme Court of the United States · 1941

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