Twin Ports Bridge Co. v. Commissioner
United States Board of Tax Appeals
1. Where a corporation pays its debts with stock of another corporation, held, the difference between total amount of debts and cost of such stock is taxable gain. 2. Commissioner's determination of basis for determination of gain or loss upon the discharge of petitioner's debts by the transfer by it of corporate stock of another corporation, and allocation of such basis to three classes of stock received by petitioner in exchange for certain of its assets, approved for lack…
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1. Where a corporation pays its debts with stock of another corporation, held, the difference between total amount of debts and cost of such stock is taxable gain. 2. Commissioner's determination of basis for determination of gain or loss upon the discharge of petitioner's debts by the transfer by it of corporate stock of another corporation, and allocation of such basis to three classes of stock received by petitioner in exchange for certain of its assets, approved for lack of evidence disclosing correct basis and proper method of allocation or apportionment of basis.
1Opinion of the Court
*353OPINION.
McMahon:
The petitioner, in order to further the enterprise in which it was interested, caused the organization of the Arrowhead *354Company in February, 1926, to carry out the contemplated project. For this purpose the petitioner conveyed or transferred certain of its assets to the Arrowhead Company, receiving in payment therefor in May, 1926, stock of the Arrowhead Company as follows: 200 shares of first preferred stock, 708 shares of second preferred stock, both of the par value of $100 per share, and 6,400 shares of common stock of no par value, the price of which was fixed at $1 per…
2Cases cited3 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
- Portuguese-American Bank of San Francisco v. WellesSupreme Court of the United States · 1916
3Cited by6 opinions
- Garland Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Moody-Warren Commercial Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Dallas Transfer & Terminal Warehouse Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Mack v. CommissionerUnited States Tax Court · 1976
- New York City Omnibus Corp. v. CommissionerUnited States Tax Court · 1948
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