Barker v. Commissioner
United States Board of Tax Appeals
1. Upon the record, held, that the transfer by the Columbia River Packers Association of its assets to the Columbia River Packers Association, Inc., for $1,578,600 and 17,540 shares of no par common stock of the Columbia River Packers Association, Inc., constituted a "reorganization" within the provisions of section 203 of the Revenue Act of 1924. 2. The fair market value of the no par value common stock of the Columbia River Packers Association, Inc., as of the date of…
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1. Upon the record, held, that the transfer by the Columbia River Packers Association of its assets to the Columbia River Packers Association, Inc., for $1,578,600 and 17,540 shares of no par common stock of the Columbia River Packers Association, Inc., constituted a "reorganization" within the provisions of section 203 of the Revenue Act of 1924. 2. The fair market value of the no par value common stock of the Columbia River Packers Association, Inc., as of the date of issuance to the Columbia River Packers Association, determined.
1Opinion of the Court
*662OPINION.
Marquette:
The petitioners contend that the principal transaction, the organization of the Columbia River Packers Association, Inc., and the transfer to it of all the assets of the Columbia River Packers Association, in exchange for cash and all of its capital stock, constituted a reorganization; that the purchase of more than two thirds of the outstanding stock of the old company at an average price of $99.98 per share established the fair market value, and that the fair market value of the shares of stock of the new company was no greater than the value of the shares of the old, less…
2Cases cited4 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Williamson v. BerrySupreme Court of the United States · 1850
- Corbett v. BurnetCourt of Appeals for the D.C. Circuit · 1931
- Pinellas Ice & Cold Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1930
3Cited by2 opinions
- Central Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1934
- Barker v. CommissionerUnited States Board of Tax Appeals · 1933