Legal Opinion

Continental Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided March 5, 1936No. Docket No. 28427Published

1. Petitioner was the sole shareholder in corporations A, B, C, and D. In 1920 corporation A sustained a net loss, while the other three corporations realized taxable net incomes. In 1921, corporations B and C, without any consideration therefor, transferred all of their assets to corporation D, which assets, in each instance, were of a value sufficient to meet the transferor's liability, as of the date of transfer, for income and profits taxes.

Read the full summary

1. Petitioner was the sole shareholder in corporations A, B, C, and D. In 1920 corporation A sustained a net loss, while the other three corporations realized taxable net incomes. In 1921, corporations B and C, without any consideration therefor, transferred all of their assets to corporation D, which assets, in each instance, were of a value sufficient to meet the transferor's liability, as of the date of transfer, for income and profits taxes. Later in 1921, corporation D, without any consideration therefor, transferred all of its assets to the petitioner, which assets were of a value…

1Opinion of the Court

CONTINENTAL OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Continental Oil Co. v. Commissioner

Docket No. 28427.

United States Board of Tax Appeals

34 B.T.A. 29; 1936 BTA LEXIS 760;

March 5, 1936, Promulgated

1. Petitioner was the sole shareholder in corporations A, B, C, and D. In 1920 corporation A sustained a net loss, while the other three corporations realized taxable net incomes. In 1921, corporations B and C, without any consideration therefor, transferred all of their assets to corporation D, which assets, in each instance, were of a value sufficient to meet the…

2Cases cited2 opinions

  1. Green River Distilling Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Continental Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1936

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API