Southern Power & Mfg. Co. v. Commissioner
United States Board of Tax Appeals
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
- Southern Power & Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1933