Legal Opinion

Green v. Commissioner

United States Board of Tax Appeals

Decided November 11, 1931No. Docket No. 53647Published

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

ROBERT D. GREEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Green v. Commissioner

Docket No. 53647.

United States Board of Tax Appeals

24 B.T.A. 719; 1931 BTA LEXIS 1603;

November 11, 1931, Promulgated

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.

E. Barrett Prettyman, Esq., for the petitioner.

Eugene Harpole, Esq., and Edwin W.…

2Cases cited5 opinions

  1. United States v. PhellisSupreme Court of the United States · 1921
  2. United States v. IshamSupreme Court of the United States · 1873
  3. Cortland Specialty Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  4. First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Green v. CommissionerUnited States Board of Tax Appeals · 1931

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