Green v. Commissioner
United States Board of Tax Appeals
Under section 203(b)(4) and 203(b)(2) of the Revenue Act of 1926 there is no recognized taxable gain to the petitioner upon the exchange of common stock in one corporation for securities and stock of two other corporations by means of certain corporate reorganizations and intermediate transactions.
1Opinion of the Court
*722OPINION.
Smith:
The petitioner contends that:
* * * If these exchanges were one transaction, they were a reorganization within the definition in the Act, since under that view, two corporations, in one transaction, transferred all their assets to two new corporations for the securities of the latter, and, in the same transaction, these securities were cross-exchanged. In that view, if these constituted hut one transaction, Community of Delaware and Power were parties to this same reorganization and the exchanges fall squarely within Section 203 (b) (2). On the other hand, if these are to be…
2Cases cited2 opinions
- United States v. PhellisSupreme Court of the United States · 1921
- United States v. IshamSupreme Court of the United States · 1873
3Cited by5 opinions
- Edison Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Minnesota Tea Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Edison Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Green v. CommissionerUnited States Board of Tax Appeals · 1931
- Redington v. CommissionerUnited States Board of Tax Appeals · 1932