Dill Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner was a manufacturing corporation, organized in 1909. Because of dissension between its majority and minority stockholders, it acquired the stockholdings of the latter in 1932. This stock was immediately retired and the stated capital reduced.
Read the full summary
1. Petitioner was a manufacturing corporation, organized in 1909. Because of dissension between its majority and minority stockholders, it acquired the stockholdings of the latter in 1932. This stock was immediately retired and the stated capital reduced. As a part of the consideration for this stock, petitioner transferred to the stockholders United States bonds, having a face value of $200,000, which had cost petitioner $202,687.51, and a then market value of $170,562.50. The contract for the acquisition of the minority stock provided for the payment of $188,000 in assets of the petitioner,…
1Opinion of the Court
*1029OPINION.
Leech:
In the first issue, respondent bases Ms disallowance of a deduction for loss on the United States bonds on that part of Begula-tions 77, article 71, which reads as follows: “® * * No gain or loss is realized by a corporation from the mere distribution of its assets in kind in'partial or complete liquidation, however they may be appreciated or depreciated in value since their acquisition * *
Similar regulations, with slight differences in wording immaterial here, have been in force since the Bevenue Act of 1918. Because such regulations had long been in force without change in the…
2Cases cited4 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- New York Trust Co. v. EisnerSupreme Court of the United States · 1921
- Weiss v. WeinerSupreme Court of the United States · 1929
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
3Cited by43 opinions
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
- Gravois Planing Mill Company, Charles A. And Florence Beckemeier v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- World Pub. Co. v. United StatesCourt of Appeals for the Tenth Circuit · 1948
38 more not listed; retrieve them via the Exa API.