Arc Realty Co. v. Commissioner
United States Tax Court
On June 24, 1932, petitioners, personal holding companies during the taxable years in issue, exchanged the gold notes which they held of the American Press for interim certificates representing 1,417 1/2 shares of Star 4 per cent second preferred stock. Said interim certificates were subject to certain restrictions. Between 1932 and 1934 additional interim certificates for 1,104 shares of Star were contributed to the capital of petitioner Lydiade.
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On June 24, 1932, petitioners, personal holding companies during the taxable years in issue, exchanged the gold notes which they held of the American Press for interim certificates representing 1,417 1/2 shares of Star 4 per cent second preferred stock. Said interim certificates were subject to certain restrictions. Between 1932 and 1934 additional interim certificates for 1,104 shares of Star were contributed to the capital of petitioner Lydiade. On July 2, 1934, petitioners received 2,521 1/2 shares of Star 4 per cent second preferred stock in exchange for their interim certificates. During…
1Opinion of the Court
Bruce, Judge:
These consolidated proceedings involve deficiencies in income tax and personal holding company surtax as follows:
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Petitioners claim overpayments of income tax as follows:
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In addition, petitioner in Docket No. 70298 claims an overpayment in income tax of $3,320.63 for the taxable year 1953, a year in which the respondent did not determine a deficiency.
Both parties have made certain concessions on brief and in the stipulation of facts. The issues remaining for decision are as follows:
1. What is the basis of Star-Times Publishing Company 4 per cent second…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Aramo-Stiftung v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Kline v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1942
22 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Arc Realty Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1961
- Estate of Ford v. CommissionerUnited States Tax Court · 1993
- Kingsford Co. v. CommissionerUnited States Tax Court · 1964
- Arc Realty Company, a Corporation v. Commissioner of Internal Revenue, Arcadia Realty Company, a Corporation v. Commissioner of Internal Revenue, Lydiade Investment Trust, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
13 more not listed; retrieve them via the Exa API.