Perata v. Commissioner
United States Board of Tax Appeals
1. A syndicate was formed in 1928 for the purpose of supplying cash to a corporation to enable it to buy certain assets. The syndicate acquired stock of the corporation and sold it at a profit and and before the close of the year had substantially completed its agreement to supply cash. The balance of the cash owing was covered by a dividend declared before the end of the year.
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1. A syndicate was formed in 1928 for the purpose of supplying cash to a corporation to enable it to buy certain assets. The syndicate acquired stock of the corporation and sold it at a profit and and before the close of the year had substantially completed its agreement to supply cash. The balance of the cash owing was covered by a dividend declared before the end of the year. Within the year the corporation released to the syndicate the remaining stock, which had been held in escrow. Held, that the syndicate was a joint venture and dividends received and the profit realized on on the sale…
1Opinion of the Court
JOHN M. PERATA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
PAUL MASONI, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
GUILIANO ROLANDELLI, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Perata v. Commissioner
Docket Nos. 57479, 57923, 58413, 67286.
United States Board of Tax Appeals
33 B.T.A. 843; 1935 BTA LEXIS 696;
December 31, 1935, Promulgated
1. A syndicate was formed in 1928 for the purpose of supplying cash to a corporation to enable it to buy certain assets. The syndicate acquired stock of the corporation and sold it at a profit and and before…
2Cases cited2 opinions
- Scatena v. CommissionerUnited States Board of Tax Appeals · 1935
- Perata v. CommissionerUnited States Board of Tax Appeals · 1935