Harrison v. Commissioner
United States Board of Tax Appeals
The H corporation transferred all of its assets (except amounts reserved and shortly thereafter paid for taxes, etc.), to the R corporation for preferred shares of the latter, a statutory reorganization, and H agreed, pursuant to the plan of reorganization, to distribute to its shareholders the preferred shares of R to be received by it and to wind up its affairs and dissolve.
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The H corporation transferred all of its assets (except amounts reserved and shortly thereafter paid for taxes, etc.), to the R corporation for preferred shares of the latter, a statutory reorganization, and H agreed, pursuant to the plan of reorganization, to distribute to its shareholders the preferred shares of R to be received by it and to wind up its affairs and dissolve. Such shares were distributed to the shareholders of H without surrender by them of their shares of H, and some months later H was dissolved. Held, that the gain realized by a shareholder of H from the distribution may…
1Opinion of the Court
OPINION.
Mubdock :
The Commissioner determined a deficiency of $21,019.38 in the petitioner’s income tax for the calendar year 1929. In determining the deficiency the Commissioner added to the total income reported $7,520.90, representing dividends which he held were received through revocable trusts. The petitioner assigned this action *967as error, and in his brief the Commissioner concedes that the income from these trusts was not taxable to the petitioner. The Commissioner also added to total income as reported “ Gain on sale $99,250”, which he explained as follows:
Gain on the sale of contracts…
2Cases cited4 opinions
- Burnet v. BrooksSupreme Court of the United States · 1933
- Boehringer v. CommissionerUnited States Board of Tax Appeals · 1933
- J. M. Harrison, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
- Winston Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by1 opinion
- Harrison v. CommissionerUnited States Board of Tax Appeals · 1934