Legal Opinion

Hollywood, Inc. v. Commissioner

United States Tax Court

Decided January 30, 1948No. Docket No. 5641Published

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

  1. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  2. Meyer v. Nator Holding Co.Supreme Court of Florida · 1931
  3. Smith v. Loftis Plumbing & Heating Co.Supreme Court of Florida · 1933
  4. Hollywood, Inc. v. CommissionerUnited States Tax Court · 1948

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