Hollywood, Inc. v. Commissioner
United States Tax Court
Petitioner's acquisition of property from two transferor-stockholders in exchange for its obligation to pay for the properties what it received upon sale up to an agreed amount, held to create a basis of its cost, the transaction not constituting a tax-free exchange under Internal Revenue Code, section 112 (b) (4) or (b) (5), nor a capital contribution under Internal Revenue Code, section 113 (a) (8) (B).
1Opinion of the Court
Hollywood, Inc., a Florida Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Hollywood, Inc. v. Commissioner
Docket No. 5641
United States Tax Court
10 T.C. 175; 1948 U.S. Tax Ct. LEXIS 274;
January 30, 1948, Promulgated
Decision will be entered for the petitioner.
Petitioner's acquisition of property from two transferor-stockholders in exchange for its obligation to pay for the properties what it received upon sale up to an agreed amount, held to create a basis of its cost, the transaction not constituting a tax-free exchange under Internal Revenue Code, section 112 (b) (4)…
2Cases cited4 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Meyer v. Nator Holding Co.Supreme Court of Florida · 1931
- Smith v. Loftis Plumbing & Heating Co.Supreme Court of Florida · 1933
- Hollywood, Inc. v. CommissionerUnited States Tax Court · 1948