Harrison v. Commissioner
United States Tax Court
Exchange of Property for Stock and Securities -- Recognition of Gain -- Sec. 112 (b) (5) -- Sec. 112 (c) (1), I. R. C. 1939. -- Partnership assets were exchanged for stock and drawing accounts in a new corporation. Held, that the drawing accounts were not securities under section 112 (b) (5) and were taxable as "other property" under section 112 (c) (1).
1Opinion of the Court
John W. Harrison, Petitioner, v. Commissioner of Internal Revenue, Respondent. Clifford F. Harrison, Petitioner, v. Commissioner of Internal Revenue, Respondent
Harrison v. Commissioner
Docket Nos. 47962, 47963
United States Tax Court
24 T.C. 46; 1955 U.S. Tax Ct. LEXIS 207;
April 20, 1955, Filed
Decisions will be entered for the respondent.
Exchange of Property for Stock and Securities -- Recognition of Gain -- Sec. 112 (b) (5) -- Sec. 112 (c) (1), I. R. C. 1939. -- Partnership assets were exchanged for stock and drawing accounts in a new corporation. Held, that the drawing accounts were not…
2Cases cited7 opinions
- Neville Coke & Chemical Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1945
- Pacific Public Service Co. v. CommissionerUnited States Tax Court · 1945
- Harrison v. CommissionerUnited States Tax Court · 1955
- Neville Coke & Chemical Co. v. CommissionerUnited States Tax Court · 1944
- Pacific Public Service Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1946
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