Adams v. Commissioner
United States Tax Court
Petitioner was the principal owner of the common stock of X corporation, which had no other class of stock and no bonds. Pursuant to a plan of recapitalization, petitioner exchanged his stock having a par value of $ 100 per share for new no par value common stock having a stated value of $ 50 per share and 20-year debenture bonds of X bearing 6 percent interest of a face amount equal to one-half of the par value of the old stock.
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Petitioner was the principal owner of the common stock of X corporation, which had no other class of stock and no bonds. Pursuant to a plan of recapitalization, petitioner exchanged his stock having a par value of $ 100 per share for new no par value common stock having a stated value of $ 50 per share and 20-year debenture bonds of X bearing 6 percent interest of a face amount equal to one-half of the par value of the old stock. No change was made in the surplus account of X and no declaration of a dividend was made. The purpose of the recapitalization was to minimize state franchise taxes…
1Opinion of the Court
Adam A. Adams, Petitioner, v. Commissioner of Internal Revenue, Respondent
Adams v. Commissioner
Docket No. 4109
United States Tax Court
4 T.C. 1186; 1945 U.S. Tax Ct. LEXIS 180;
April 26, 1945, Promulgated *
Decision will be entered under Rule 50.
Petitioner was the principal owner of the common stock of X corporation, which had no other class of stock and no bonds. Pursuant to a plan of recapitalization, petitioner exchanged his stock having a par value of $ 100 per share for new no par value common stock having a stated value of $ 50 per share and 20-year debenture bonds of X bearing 6 percent…
2Cases cited7 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Crown Cork International Corp. v. CommissionerUnited States Tax Court · 1944
- Bazley v. CommissionerUnited States Tax Court · 1945
- Wellhouse v. CommissionerUnited States Tax Court · 1944
- Adams v. CommissionerUnited States Tax Court · 1945
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