Redington v. Commissioner
United States Board of Tax Appeals
1. During 1928 the petitioner exchanged certain shares of common stock in a Colorado corporation which he had acquired subsequent to March 1, 1913, at a cost of $40,000, with a Delaware corporation for certain shares of its common stock having a fair market value of $83,549 on the date of the exchange.
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1. During 1928 the petitioner exchanged certain shares of common stock in a Colorado corporation which he had acquired subsequent to March 1, 1913, at a cost of $40,000, with a Delaware corporation for certain shares of its common stock having a fair market value of $83,549 on the date of the exchange. By purchase and other exchanges the Delaware corporation acquired the remainder of the outstanding common stock of the Colorado corporation, but no part of the outstanding preferred stock. The Colorado corporation was not dissolved as a result of the transaction, but continued as a going…
1Opinion of the Court
*709OPINION.
Trammell :
The petitioner contends that no taxable profit resulted from the exchange of his stock in the Windsor Company for stock in the Beatrice Company as set out in our findings of fact, since the acquisition by the Beatrice Company of all of the common stock of the Windsor Company was a reorganization within the meaning of the term as used in section 112 (i) (1) of the Revenue Act of 1928. The respondent denies the correctness of this contention of the petitioner.
Pertinent provisions of the Revenue Act of 1928 are as follows: Sec. 111. DETERMINATION OE AMOUNT OE GAIN OR DOSS.(a)…
2Cases cited1 opinion
- Marr v. United StatesSupreme Court of the United States · 1925
3Cited by2 opinions
- Burns v. CommissionerUnited States Board of Tax Appeals · 1934
- Redington v. CommissionerUnited States Board of Tax Appeals · 1932