Reeves v. Commissioner
United States Tax Court
In 1968 and 1969, X corporation acquired approximately 8 percent of the stock of Y corporation from the latter's shareholders for cash. Such acquisitions were made for the purpose of furthering the efforts of X corporation to acquire Y corporation.
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In 1968 and 1969, X corporation acquired approximately 8 percent of the stock of Y corporation from the latter's shareholders for cash. Such acquisitions were made for the purpose of furthering the efforts of X corporation to acquire Y corporation. In 1970, X corporation acquired more than 80 percent of Y corporation's then-issued and outstanding stock from the latter's shareholders in exchange solely for voting stock of X. The 1970 acquisition, in and of itself, satisfied the control requirement of sec. 368(c), I.R.C. 1954. Held, as a matter of law, X corporation's prior cash purchases of Y…
1Opinion of the Court
OPINION
Tannenwald, Judge:
This matter is before the Court on petitioners’ motion for summary judgment, pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The sole issue for our decision is whether the acquisition of stock of Hartford Fire Insurance Co. (Hartford) by International Telephone & Telegraph Corp. (ITT) qualified, as a matter of law, as a reorganization within the meaning of section 368(a)(1)(B),2 with the result that petitioners are not taxable on any gain on the receipt of stock of ITT in exchange for their Hartford stock. See sec. 354(a).
The table below sets forth…
2Cases cited29 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. BrownSupreme Court of the United States · 1965
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
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3Cited by6 opinions
- Arden S. Heverly and Sophia S. Heverly v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Eldon S. Chapman v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1980
- Clark v. CommissionerUnited States Tax Court · 1986
- Pierson v. United StatesDistrict Court, D. Delaware · 1979
- Clark v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.