Carman v. Commissioner
United States Tax Court
Petitioner, in the recapitalization of company A, exchanged as of the date of January 1, 1939, A's bonds of a face value of $ 25,000 for bonds and stock of the reorganized company A. As of such date there was accrued unpaid interest on such bonds in the amount of $ 3,590.06. The effective date of the reorganization was January 1, 1939, but the actual exchange of the securities was not made until 1944. On the latter date petitioner also received from the reorganized company A…
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Petitioner, in the recapitalization of company A, exchanged as of the date of January 1, 1939, A's bonds of a face value of $ 25,000 for bonds and stock of the reorganized company A. As of such date there was accrued unpaid interest on such bonds in the amount of $ 3,590.06. The effective date of the reorganization was January 1, 1939, but the actual exchange of the securities was not made until 1944. On the latter date petitioner also received from the reorganized company A a certain amount of cash, the cash so received representing adjustment payments in lieu of amounts which petitioner…
1Opinion of the Court
William W. Carman, Petitioner, v. Commissioner of Internal Revenue, Respondent
Carman v. Commissioner
Docket No. 16796
United States Tax Court
13 T.C. 1029; 1949 U.S. Tax Ct. LEXIS 10;
December 21, 1949, Promulgated
Decision will be entered under Rule 50.
Petitioner, in the recapitalization of company A, exchanged as of the date of January 1, 1939, A's bonds of a face value of $ 25,000 for bonds and stock of the reorganized company A. As of such date there was accrued unpaid interest on such bonds in the amount of $ 3,590.06. The effective date of the reorganization was January 1, 1939, but the…
2Cases cited8 opinions
- Ecker v. Western Pacific R. Corp.Supreme Court of the United States · 1943
- Bailey v. . County of BuchananNew York Court of Appeals · 1889
- Knapp Monarch Co. v. CommissionerUnited States Tax Court · 1942
- Okonite Co. v. CommissionerUnited States Tax Court · 1945
- Globe-News Publishing Co. v. CommissionerUnited States Tax Court · 1944
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