Ortmayer v. Commissioner
United States Tax Court
1. On July 2, 1948, Cunningham-Ortmayer Company issued 750 shares of $ 1-par-value common stock (having a market value of $ 350 per share) and 750 ten-year 6 per cent debentures in the face amount of $ 100 each (having a market value of $ 100 each) in a pro rata exchange for the surrender by its shareholders of the 750 outstanding $ 100-par-value shares of common stock and the payment of $ 1 with each share surrendered.
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1. On July 2, 1948, Cunningham-Ortmayer Company issued 750 shares of $ 1-par-value common stock (having a market value of $ 350 per share) and 750 ten-year 6 per cent debentures in the face amount of $ 100 each (having a market value of $ 100 each) in a pro rata exchange for the surrender by its shareholders of the 750 outstanding $ 100-par-value shares of common stock and the payment of $ 1 with each share surrendered. Petitioners held and exchanged 748 shares of the company's 750 outstanding common stock. Of these shares, 374 had been acquired in 1945 from a deceased creditor's estate for $…
1Opinion of the Court
Fisher, Judge:
This proceeding involves deficiencies in income taxes determined against Carl Gr. and Hilda B. Ortmayer as follows:
"Sear Deficiency
1948_$37,921.32
1949- 441. 22
By amended answer, respondent claims an increased deficiency for the year 1948 in the amount of $13,081.42. The material part of the claim is set forth in the margin.1 The respondent, in said amended answer, also sets forth an alternative claim for increased deficiency in the amount of $450.72 for the year 1948 which it is unnecessary to set forth herein in the light of our determination.
The issues to he decided are: (1)…
2Cases cited10 opinions
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- Kaplan v. CommissionerUnited States Tax Court · 1953
- Nelson v. CommissionerUnited States Tax Court · 1952
5 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Graf v. CommissionerUnited States Tax Court · 1983
- Griffith v. CommissionerUnited States Tax Court · 1961
- Katharine T. Hyde v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Hyde v. CommissionerUnited States Tax Court · 1961
- Ostrov v. CommissionerUnited States Tax Court · 1969
9 more not listed; retrieve them via the Exa API.