Legal Opinion
Pierson v. United States
District Court, D. Delaware
Decided April 24, 1979No. Civ. A. 75-218PublishedCited by 5 opinions
1Opinion of the Court
OPINION
MURRAY M. SCHWARTZ, District Judge.
The plaintiff in this action, John Lewis Pierson, is one of over 17,000 former shareholders of the Hartford Insurance Company (“Hartford”) who exchanged their Hartford stock for shares of the International Telephone and Telegraph Corporation (“ITT”) Series N voting convertible preferred stock, pursuant to an exchange offer made by ITT in 1970. Mr. Pierson contends that this exchange offer qualified as a tax-free reorganization under Sections 354(a)(1) and 368(a)(1)(B) of the Internal Revenue Code of 1954. 1 Having determined that the exchange offer…
2Cases cited20 opinions
- 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
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
15 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- In Re Acushnet River & New Bedford Harbor Proceedings Re Alleged PCB PollutionDistrict Court, D. Massachusetts · 1989
- 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
- Clark v. CommissionerUnited States Tax Court · 1986