Fairless v. Commissioner of Internal Revenue

SIMONS, Circuit Judge.

The petitioners in the six cases, grouped under the above style, were all stockholders in the Union Finance Company, an Ohio corporation, which by corporate action taken in October, 1922, transferred all of its assets to the Metropolitan Securities Company on January 4,1923. The transferor in exchange received a certificate for 5,886 shares of the preferred stock of the purchasing company, and shortly- thereafter distributed the stock through a transfer agent to its own stockholders, share for share. The Union Finance Company thereupon ceased to do business, though it…