Brush-Moore Newspapers, Inc. v. Commissioner
United States Board of Tax Appeals
The taxpayer in 1931, being in financial difficulties and desiring to avoid annual principal payments of $50,000 on notes given by it in 1930 upon the purchase of certain shares of stock, exchanged $400,000 of such notes for 4,000 shares of its own second preferred stock, with the understanding that if dividends thereon were not paid in any quarter a fixed amount should be paid as interest, and, in addition, such amount as its directors deemed necessary for the support and…
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The taxpayer in 1931, being in financial difficulties and desiring to avoid annual principal payments of $50,000 on notes given by it in 1930 upon the purchase of certain shares of stock, exchanged $400,000 of such notes for 4,000 shares of its own second preferred stock, with the understanding that if dividends thereon were not paid in any quarter a fixed amount should be paid as interest, and, in addition, such amount as its directors deemed necessary for the support and maintenance of the payee of such notes or his wife, the payee being guaranteed by taxpayer against any loss resulting…
1Opinion of the Court
THE BRUSH-MOORE NEWSPAPERS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Brush-Moore Newspapers, Inc. v. Commissioner
Docket Nos. 86732, 86946.
United States Board of Tax Appeals
37 B.T.A. 787; 1938 BTA LEXIS 985;
April 29, 1938, Promulgated
The taxpayer in 1931, being in financial difficulties and desiring to avoid annual principal payments of $50,000 on notes given by it in 1930 upon the purchase of certain shares of stock, exchanged $400,000 of such notes for 4,000 shares of its own second preferred stock, with the understanding that if dividends thereon were not paid in…
2Cases cited1 opinion
- Brush-Moore Newspapers, Inc. v. CommissionerUnited States Board of Tax Appeals · 1938