San Antonio Transit Co. v. Commissioner
United States Tax Court
1. The phrase "property of a corporation" as used in section 112 (b) (10), I. R. C. 1939, construed as not requiring that "all" or "substantially all" of transferor's property be included in order to qualify for nonrecognition provisions of statute and, because of a statutory change, the doctrine of collateral estoppel held not applicable to this and other issues presented. 2. Held, on facts, that property was acquired by petitioner "solely in exchange for its stock or…
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1. The phrase "property of a corporation" as used in section 112 (b) (10), I. R. C. 1939, construed as not requiring that "all" or "substantially all" of transferor's property be included in order to qualify for nonrecognition provisions of statute and, because of a statutory change, the doctrine of collateral estoppel held not applicable to this and other issues presented. 2. Held, on facts, that property was acquired by petitioner "solely in exchange for its stock or securities" within the intendment of said section 112 (b) (10). 3. Requisite continuity of interest under said section 112…
1Opinion of the Court
San Antonio Transit Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
San Antonio Transit Co. v. Commissioner
Docket Nos. 15411, 41321
United States Tax Court
30 T.C. 1215; 1958 U.S. Tax Ct. LEXIS 90;
September 11, 1958, Filed
Decisions will be entered under Rule 50.
1. The phrase "property of a corporation" as used in section 112 (b) (10), I. R. C. 1939, construed as not requiring that "all" or "substantially all" of transferor's property be included in order to qualify for nonrecognition provisions of statute and, because of a statutory change, the doctrine of collateral…
2Cases cited19 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Northern Pacific Railway Co. v. BoydSupreme Court of the United States · 1913
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
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