Legal Opinion
Lloyd-Smith v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 6, 1941No. 12PublishedCited by 36 opinions
1Opinion of the Court
AUGUSTUS N. HAND, Circuit Judge.
In 1932 the above taxpayer, Marjorie Fleming Lloyd-Smith, transferred to Jorwil Corporation certain assets belonging to her which had a cost basis of $2,636,778.-49, and a fair market value at the time of tránsfer of $477,606.19. In exchange Jorwil Corporation issued to her its capital stock of the par value of $15,000 and its unsecured two year 6% promissory note for $303,000. In 1933 the note was split into two notes, one for $70,000 and the other for $233,000. In the same year the $70,-000 note was sold for $70,000 in cash. Both the Commissioner and the…
2Cases cited8 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Cortland Specialty Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
- Helvering v. WattsSupreme Court of the United States · 1935
- Moder v. United StatesSupreme Court of the United States · 1933
3 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Rushing v. CommissionerUnited States Tax Court · 1972
- Skenandoa Rayon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
- Imel v. CommissionerUnited States Tax Court · 1973
- Stamos v. CommissionerUnited States Tax Court · 1954
- Shea v. CommissionerUnited States Tax Court · 1961
31 more not listed; retrieve them via the Exa API.