Legal Opinion

Southern Power & Mfg. Co. v. Commissioner

United States Board of Tax Appeals

Decided December 26, 1933No. Docket No. 57512Published

The petitioner acquired certain assets by the issue of its stock to three prior owners thereof in exact proportions to their interests therein. Held, that the basis for determining gain or loss on the subsequent sale of all its assets is cost to such prior owners, plus any capital addition after acquisition.

1Opinion of the Court

SOUTHERN POWER & MANUFACTURING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Southern Power & Mfg. Co. v. Commissioner

Docket No. 57512.

United States Board of Tax Appeals

29 B.T.A. 628; 1933 BTA LEXIS 908;

December 26, 1933, Promulgated

The petitioner acquired certain assets by the issue of its stock to three prior owners thereof in exact proportions to their interests therein. Held, that the basis for determining gain or loss on the subsequent sale of all its assets is cost to such prior owners, plus any capital addition after acquisition.

John J. Finnorn, Esq., for the…

2Cases cited1 opinion

  1. Southern Power & Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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