Wolf Envelope Co. v. Commissioner
United States Tax Court
A corporation had outstanding 5 per cent debenture shares, class A and class B common stock. Class A shares were principally held by inactive and absentee stockholders and class B by the active managing stockholders. Class A shares carried a fixed cumulative dividend and a liquidating value of $ 100 each. Class B shares carried the right to any further earnings and to the remaining assets on dissolution. Both classes carried voting rights.
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A corporation had outstanding 5 per cent debenture shares, class A and class B common stock. Class A shares were principally held by inactive and absentee stockholders and class B by the active managing stockholders. Class A shares carried a fixed cumulative dividend and a liquidating value of $ 100 each. Class B shares carried the right to any further earnings and to the remaining assets on dissolution. Both classes carried voting rights. Pursuant to agreement, the stockholders adopted a plan of reorganization under which new 5 per cent 20-year debenture bonds were issued to retire the class…
1Opinion of the Court
OPINION.
Tietjens, Judge:
The principal issue concerns the tax effect of an exchange of securities of the Wolf Envelope Company carried out July 1, 1945. There were three types of exchanges, two of which are in controversy. The exchange of class B no par value common stock for new $10 par value common at 20 shares for one is not in question. The challenged exchanges were those in which 5 per cent debenture bonds of the 1945 issue were received. The holders of debenture shares of the 1940 issue exchanged them for debenture bonds of the 1945 issue of the same face amount, but containing terms and…
2Cases cited9 opinions
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Commissioner of Internal Revenue v. Neustadt's TrustCourt of Appeals for the Second Circuit · 1942
- Bazley v. CommissionerUnited States Tax Court · 1945
- Bazley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
- Globe-News Publishing Co. v. CommissionerUnited States Tax Court · 1944
4 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Gallagher v. CommissionerUnited States Tax Court · 1962
- Becher v. CommissionerUnited States Tax Court · 1954
- Estate of Parshelsky v. CommissionerCourt of Appeals for the Second Circuit · 1962
- Hickok v. CommissionerUnited States Tax Court · 1959
- Penfield v. DavisDistrict Court, N.D. Alabama · 1952
16 more not listed; retrieve them via the Exa API.