Spangler v. Commissioner
United States Board of Tax Appeals
REORGANIZATION - RECOGNITION OF GAIN OR LOSS. - A corporation, a national bank, transferred to a new corporation which it caused to be organized, part of its assets, to wit, $300,000 in cash, in exchange for all of the new company's stock, which it immediately distributed to its stockholders in the form of beneficial interests, without surrender of their stock.
Read the full summary
REORGANIZATION - RECOGNITION OF GAIN OR LOSS. - A corporation, a national bank, transferred to a new corporation which it caused to be organized, part of its assets, to wit, $300,000 in cash, in exchange for all of the new company's stock, which it immediately distributed to its stockholders in the form of beneficial interests, without surrender of their stock. Held, this was a reorganization under section 112(i)(1)(B), Revenue Act of 1928, and that no gain to the stockholders may be recognized from the receipt of their beneficial interests in the new stock. Sec. 112(g); John G. Lonsdale,11…
1Opinion of the Court
GEORGIA M. SPANGLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
J. W. SPANGLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Spangler v. Commissioner
Docket Nos. 56320, 56321.
United States Board of Tax Appeals
29 B.T.A. 263; 1933 BTA LEXIS 979;
October 31, 1933, Promulgated
REORGANIZATION - RECOGNITION OF GAIN OR LOSS. - A corporation, a national bank, transferred to a new corporation which it caused to be organized, part of its assets, to wit, $300,000 in cash, in exchange for all of the new company's stock, which it immediately distributed to its stockholders in…
2Cases cited3 opinions
- Andrews v. CommissionerUnited States Board of Tax Appeals · 1932
- Hopkins v. CommissionerUnited States Board of Tax Appeals · 1933
- Spangler v. CommissionerUnited States Board of Tax Appeals · 1933