Bus & Transport Securities Corp. v. Helvering, Commissioner of Internal Revenue

Petitioner — Bus and Transport Securities Corporation — challenges a deficiency income tax assessment for 1929, and says that the transaction from which the alleged taxable gain arose was reorganization within § 112, Rev. Act, 1928. Paragraphs (b) (4), (i) (1) and (i) (2) are specially relied upon. †

Jacobus owned practically all shares of two corporations, herein designated “A” and “ B,” which operated bus lines. The Public Service Corporation of New Jersey— the projector — desired to control these lines; and to that end engineered the following plan.

Public Service Coordinated Transport…