Prudential Loan Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner, succeeding to assets of predecessor corporation in a nontaxable reorganization under section 112, Revenue Act of 1928, held, on the facts to be entitled to offset against its income a loss on the sale of transferred property computed by using predecessor's basis, where the evidence sufficiently demonstrates ownership of the property by predecessor and transfer to petitioner prior to consummation of the sale, which had been previously contracted for by…
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1. Petitioner, succeeding to assets of predecessor corporation in a nontaxable reorganization under section 112, Revenue Act of 1928, held, on the facts to be entitled to offset against its income a loss on the sale of transferred property computed by using predecessor's basis, where the evidence sufficiently demonstrates ownership of the property by predecessor and transfer to petitioner prior to consummation of the sale, which had been previously contracted for by predecessor's principal stockholders. 2. Property (shares of stock) found not to have been worthless in or prior to year of…
1Opinion of the Court
PRUDENTIAL LOAN COMPANY, A MINNESOTA CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Prudential Loan Co. v. Commissioner
Docket No. 78869.
United States Board of Tax Appeals
37 B.T.A. 975; 1938 BTA LEXIS 958;
June 1, 1938, Promulgated
1. Petitioner, succeeding to assets of predecessor corporation in a nontaxable reorganization under section 112, Revenue Act of 1928, held, on the facts to be entitled to offset against its income a loss on the sale of transferred property computed by using predecessor's basis, where the evidence sufficiently demonstrates ownership of the…
2Cases cited1 opinion
- Prudential Loan Co. v. CommissionerUnited States Board of Tax Appeals · 1938