Role v. Commissioner
United States Tax Court
In 1967, petitioners acquired most of the stock of Keystone which qualified as "section 1244 stock" under sec. 1244, I.R.C. 1954. In 1969, Keystone reincorporated in Delaware and changed its name to KBSI.
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In 1967, petitioners acquired most of the stock of Keystone which qualified as "section 1244 stock" under sec. 1244, I.R.C. 1954. In 1969, Keystone reincorporated in Delaware and changed its name to KBSI. In 1971, KBSI merged into Micro-Scan, a small publicly held New York corporation, and the surviving corporation was renamed KMS (N.Y.). Shortly thereafter, KMS (N.Y.) was reincorporated in Delaware and merged into a newly created shell corporation, KMS (Del.). In 1973, KMS (Del.) was adjudicated bankrupt. Held: The KMS (N.Y.) stock received by petitioners pursuant to the merger of KBSI into…
1Opinion of the Court
Theodore and Josephine V. Role, Petitioners v. Commissioner of Internal Revenue, Respondent; Robert J. Swartz and Adele M. Swartz, Petitioners v. Commissioner of Internal Revenue, Respondent
Role v. Commissioner
Docket Nos. 8577-76, 9087-76
United States Tax Court
70 T.C. 341; 1978 U.S. Tax Ct. LEXIS 113;
May 25, 1978, Filed
Decisions will be entered for the respondent.
In 1967, petitioners acquired most of the stock of Keystone which qualified as "section 1244 stock" under sec. 1244, I.R.C. 1954. In 1969, Keystone reincorporated in Delaware and changed its name to KBSI. In 1971, KBSI merged into…
2Cases cited17 opinions
- Koshland v. HelveringSupreme Court of the United States · 1936
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Bazley v. CommissionerSupreme Court of the United States · 1947
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
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