Robinson v. Commissioner
United States Board of Tax Appeals
In the circumstances herein the petitioner realized no profit from the exchange of certain property for the stock of a corporation.
1Opinion of the Court
*756OPINION.
Lansdon:
In support of his appeal the petitioner urges the following propositions: (1) That the transfer of the assets by himself and associates to the Bermuda Coal Co. in exchange for which they received the stock which the Commissioner found resulted in a taxable gain to him, took place on June 14,1922, the date of the first meeting of the board of directors, at which time they owned all of the capital stock of the corporation, and were in control of it, within the provisions of section 202(c)(3) of the Revenue Act of 1921; and that *757under these circumstances the transaction gave rise…
2Cases cited19 opinions
- Dickerman v. Northern Trust Co.Supreme Court of the United States · 1900
- Seymour v. Spring Forest Cemetery Ass'nNew York Court of Appeals · 1895
- Pittsburg Mining Co. v. SpoonerWisconsin Supreme Court · 1889
- Ex Parte McDonoughCalifornia Supreme Court · 1915
- Burbank v. DennisCalifornia Supreme Court · 1894
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3Cited by3 opinions
- Hall v. CommissionerUnited States Board of Tax Appeals · 1934
- Perfex Corp. v. CommissionerUnited States Board of Tax Appeals · 1932
- Robinson v. CommissionerUnited States Board of Tax Appeals · 1930