Pinellas Ice & Cold Storage Co. v. Commissioner
United States Board of Tax Appeals
Held that the petitioner sold its assets for cash paid and to be paid in the future and the transaction does not come within the reorganization provisions of the Revenue Act of 1926 relating to exchanges.
1Opinion of the Court
*430OPINION.
TRAMMell:
It is the contention of the petitioner that the transaction here involved comes within the reorganization provisions of the Kevenue Act of 1926 and that, the proceeds of the sale or transfer having been distributed pursuant to a plan of reorganization, there was no taxable gain.
The pertinent provisions of the statute are:
Seo. 203. (a) Upon the sale or exchange of property the entire amount of the gain or loss, determined under section 202, shall be recognized, except as hereinafter provided in this section.
and the following subdivisions of section 203: (b) (3); (d) (1); (e)…
2Cases cited6 opinions
- Williamson v. BerrySupreme Court of the United States · 1850
- Bank of the United States v. DANIELSupreme Court of the United States · 1838
- Lyman v. President of the Bank of the United StatesSupreme Court of the United States · 1852
- Peacock v. Our Home Life InsuranceSupreme Court of Florida · 1917
- King v. McConnellSupreme Court of Florida · 1909
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Barker v. CommissionerUnited States Board of Tax Appeals · 1933
- Barker v. CommissionerUnited States Board of Tax Appeals · 1933
- Pinellas Ice & Cold Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1930