W. & K. Holding Corp. v. Commissioner
United States Board of Tax Appeals
1. Securities were transferred to a corporation for shares of its preferred stock and the recipients of the stock expected, but had no agreement, to receive at some future time a fixed amount of cash upon redemption of the stock.
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1. Securities were transferred to a corporation for shares of its preferred stock and the recipients of the stock expected, but had no agreement, to receive at some future time a fixed amount of cash upon redemption of the stock. Held, the transaction was a nontaxable exchange within section 112(b)(5) and not a sale of the securities with payment deferred. 2. A distribution in redemption of 60 percent of its common stock, made by a corporation without any intention of liquidating or of accomplishing any business need, but solely for the purpose of distributing an extraordinarily large profit…
1Opinion of the Court
W. & K. HOLDING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
HERMAN KNOBLOCH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
WESLEY E. KNOBLOCH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
HARVEY W. PEACE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
DAVID C. KNOBLOCH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
W. & K. Holding Corp. v. Commissioner
Docket Nos. 81216, 87275, 87276, 87277, 87278.
United States Board of Tax Appeals
38 B.T.A. 830; 1938 BTA LEXIS 820;
October 12, 1938, Promulgated
1. Securities…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Massachusetts v. MellonSupreme Court of the United States · 1923
- Heald v. District of ColumbiaSupreme Court of the United States · 1922
- Natwick v. CommissionerUnited States Board of Tax Appeals · 1937
- Weyerhaeuser v. CommissionerUnited States Board of Tax Appeals · 1935
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