R. H. Perry & Co. v. Commissioner
United States Board of Tax Appeals
1. INVESTED CAPITAL. - Each one of six corporations engaged in the same line of business, transferred its business in a particular locality to a newly organized corporation. The properties conveyed consisted of fixed assets, cash and intangibles.
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1. INVESTED CAPITAL. - Each one of six corporations engaged in the same line of business, transferred its business in a particular locality to a newly organized corporation. The properties conveyed consisted of fixed assets, cash and intangibles. For these assets the new corporation issued 93 per cent of its preferred and 78 per cent of its common stock, but neither one of the selling corporations received for its assets conveyed as much as 50 per cent of the total of either preferred or common stock. Held, that the restriction as to invested capital under section 331 of the Act of 1918 did…
1Opinion of the Court
R. H. PERRY & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
R. H. Perry & Co. v. Commissioner
Docket No. 9467.
United States Board of Tax Appeals
12 B.T.A. 328; 1928 BTA LEXIS 3557;
June 4, 1928, Promulgated
1. INVESTED CAPITAL. - Each one of six corporations engaged in the same line of business, transferred its business in a particular locality to a newly organized corporation. The properties conveyed consisted of fixed assets, cash and intangibles. For these assets the new corporation issued 93 per cent of its preferred and 78 per cent of its common stock, but neither one of…
2Cases cited1 opinion
- R. H. Perry & Co. v. CommissionerUnited States Board of Tax Appeals · 1928