Legal Opinion

Spangler v. Commissioner

United States Board of Tax Appeals

Decided October 31, 1933No. Docket Nos. 56320, 56321Published

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.

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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

  1. Andrews v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Hopkins v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Spangler v. CommissionerUnited States Board of Tax Appeals · 1933

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