Flushing Nurseries Co. v. Commissioner
United States Board of Tax Appeals
Petitioner in 1926 acquired all the stock of two other corporations in exchange for its stock. The assets of these corporations were then transferred to petitioner and the stock of these corporations was canceled. Following these transactions, petitioner owned the assets of the two other corporations and its stock was owned by the same persons who had formerly owned the stock of the other corporations.
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Petitioner in 1926 acquired all the stock of two other corporations in exchange for its stock. The assets of these corporations were then transferred to petitioner and the stock of these corporations was canceled. Following these transactions, petitioner owned the assets of the two other corporations and its stock was owned by the same persons who had formerly owned the stock of the other corporations. Held, that the assets of the other corporations were acquired "in connection with a reorganization" under section 204(a)(7) of the Revenue Act of 1926, and the basis for determining the gain…
1Opinion of the Court
*939OriNION.
Smith :
Petitioner contends that it realized no gain upon the sale of certain real estate acquired in the manner set forth in our findings from the Land Company, since the fair market value of the real estate on the date of acquisition (January 5, 1926) was the amount of the consideration received on the date of the sale (January 6, 1926). The respondent contends that petitioner acquired the property in connection with a reorganization and that the basis to be used for computing the gain upon the sale is the cost of the property to the Land Company, such cost being stipulated as…
2Cited by3 opinions
- San Joaquin Fruit & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Flushing Nurseries Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- San Joaquin Fruit & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1933