United Gas Improv. Co. v. Commissioner
United States Tax Court
1. Debentures, together with interest accrued but unpaid, were exchanged in 1947, pursuant to a reorganization, for new securities in an amount less than the cost of the old debentures.
Read the full summary
1. Debentures, together with interest accrued but unpaid, were exchanged in 1947, pursuant to a reorganization, for new securities in an amount less than the cost of the old debentures. Held: Interest accrued but unpaid is an integral part of a debenture and such debenture, together with the interest accrued, constitutes a "security" within the meaning of section 112 (b) (3) of the Internal Revenue Code of 1939. No gain, therefore, is recognized in the exchange of old debentures, plus interest accrued on same, for new securities in a section 112 (g) reorganization. 2. Parent corporation…
1Opinion of the Court
United Gas Improvement Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
United Gas Improv. Co. v. Commissioner
Docket No. 39315
United States Tax Court
25 T.C. 229; 1955 U.S. Tax Ct. LEXIS 59;
October 31, 1955, Filed
Decision will be entered under Rule 50.
1. Debentures, together with interest accrued but unpaid, were exchanged in 1947, pursuant to a reorganization, for new securities in an amount less than the cost of the old debentures. Held: Interest accrued but unpaid is an integral part of a debenture and such debenture, together with the interest accrued, constitutes a…
2Cases cited5 opinions
- Atlantic Coast Line R. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1936
- Newark Milk & Cream Co. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1929
- Commissioner of Internal Revenue v. Carman. Carman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- United Gas Improv. Co. v. CommissionerUnited States Tax Court · 1955
- Bernstein v. CommissionerUnited States Tax Court · 1954