Fry v. Commissioner
United States Tax Court
1. Pursuant to a plan of reorganization, a state bank in 1933 subscribed to and received all of the capital stock of a newly organized national bank, except directors' qualifying shares, and the new bank acquired part of the old bank's assets. Immediately thereafter, the old bank was in control of the new as control is defined in section 112 (h) of the Internal Revenue Code.
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1. Pursuant to a plan of reorganization, a state bank in 1933 subscribed to and received all of the capital stock of a newly organized national bank, except directors' qualifying shares, and the new bank acquired part of the old bank's assets. Immediately thereafter, the old bank was in control of the new as control is defined in section 112 (h) of the Internal Revenue Code. The stock of the new bank was pledged to the Reconstruction Finance Corporation by the old bank to secure the loan it had received from RFC and used for the purchase of the new bank stock. In 1939 RFC released one-half of…
1Opinion of the Court
W. N. Fry, Petitioner, v. Commissioner of Internal Revenue, Respondent
Fry v. Commissioner
Docket No. 758
United States Tax Court
5 T.C. 1058; 1945 U.S. Tax Ct. LEXIS 42;
November 14, 1945, Promulgated
Decision will be entered for the petitioner.
1. Pursuant to a plan of reorganization, a state bank in 1933 subscribed to and received all of the capital stock of a newly organized national bank, except directors' qualifying shares, and the new bank acquired part of the old bank's assets. Immediately thereafter, the old bank was in control of the new as control is defined in section 112 (h) of the…
2Cases cited5 opinions
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Heller v. CommissionerUnited States Tax Court · 1943
- Morley Cypress Trust, Schedule "B" v. CommissionerUnited States Tax Court · 1944
- Fry v. CommissionerUnited States Tax Court · 1945
- Hoboken Land & Improv. Co. v. CommissionerUnited States Board of Tax Appeals · 1942