Legal Opinion

Johnson v. Commissioner

United States Board of Tax Appeals

Decided March 14, 1941No. Docket No. 97388Published

Petitioner subscribed to shares of stock in a realty corporation. In 1935 the shareholders of the corporation voted to dissolve the corporation and appointed a liquidator. The liquidator transferred substantially all corporate property to mortgage creditors and in order to pay other creditors and liquidation expenses, and to place the shareholders upon an equal basis, made calls upon the subscribers for additional payments on their subscriptions.

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Petitioner subscribed to shares of stock in a realty corporation. In 1935 the shareholders of the corporation voted to dissolve the corporation and appointed a liquidator. The liquidator transferred substantially all corporate property to mortgage creditors and in order to pay other creditors and liquidation expenses, and to place the shareholders upon an equal basis, made calls upon the subscribers for additional payments on their subscriptions. The subscribers whose subscriptions were not fully paid, including petitioner, received no distribution of physical assets. The liquidator canceled…

1Opinion of the Court

EARLE F. JOHNSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Johnson v. Commissioner

Docket No. 97388.

United States Board of Tax Appeals

43 B.T.A. 960; 1941 BTA LEXIS 1427;

March 14, 1941, Promulgated

Petitioner subscribed to shares of stock in a realty corporation. In 1935 the shareholders of the corporation voted to dissolve the corporation and appointed a liquidator. The liquidator transferred substantially all corporate property to mortgage creditors and in order to pay other creditors and liquidation expenses, and to place the shareholders upon an equal basis, made calls…

2Cases cited1 opinion

  1. Johnson v. CommissionerUnited States Board of Tax Appeals · 1941

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