Legal Opinion

Ballwood Co. v. Commissioner

United States Board of Tax Appeals

Decided May 4, 1934No. Docket No. 66312Published

Under an agreement entered into between Corporation A (the petitioner) and Corporation B, Corporation A caused to be organized Corporation C to which it transferred a part of its assets, approximately 29 percent, in exchange for all of Corporation C's capital stock. Thereupon, Corporation A transferred all of such capital stock to Corporation B in exchange for a part, approximately 18 percent, of its capital stock, which it distributed as a dividend to its sole stockholder.

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Under an agreement entered into between Corporation A (the petitioner) and Corporation B, Corporation A caused to be organized Corporation C to which it transferred a part of its assets, approximately 29 percent, in exchange for all of Corporation C's capital stock. Thereupon, Corporation A transferred all of such capital stock to Corporation B in exchange for a part, approximately 18 percent, of its capital stock, which it distributed as a dividend to its sole stockholder. Held, that the exchange by Corporation A of the stock of Corporation C for shares of stock of Corporation B did not…

1Opinion of the Court

THE BALLWOOD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ballwood Co. v. Commissioner

Docket No. 66312.

United States Board of Tax Appeals

30 B.T.A. 644; 1934 BTA LEXIS 1291;

May 4, 1934, Promulgated

Under an agreement entered into between Corporation A (the petitioner) and Corporation B, Corporation A caused to be organized Corporation C to which it transferred a part of its assets, approximately 29 percent, in exchange for all of Corporation C's capital stock. Thereupon, Corporation A transferred all of such capital stock to Corporation B in exchange for a part,…

2Cases cited1 opinion

  1. Ballwood Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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