New York Fruit Auction Corp. v. Commissioner
United States Tax Court
Corporation A acquired all the stock of corporation B. Corporation A was then merged into corporation B. Held, neither sec. 334(b)(2), I.R.C. 1954, nor the "integrated transaction" doctrine applies to permit a step-up in basis of the assets of corporation B.
1Opinion of the Court
Tannenwald, Chief Judge:
Respondent determined deficiencies in petitioner’s Federal income tax in the amounts of $27,007, $24,480, and $23,945 for the taxable years 1974,1975, and 1976, respectively. The sole issue for our determination is whether petitioner is entitled to a stepped-up basis in its assets, equal to the price paid for petitioner’s stock by Cayuga Corp.1
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioner New York Fruit Auction Corp. is a corporation with offices located at Hunts Point Food Center, Bronx, N.Y. Prior to and during the years…
2Cases cited18 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
13 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- New York Fruit Auction Corp. v. CommissionerUnited States Tax Court · 1982