Legal Opinion

France Co. v. Commissioner

United States Board of Tax Appeals

Decided January 3, 1934No. Docket No. 64869Published

A corporation, owning by cash purchase all the shares of its subsidiary, received all the subsidiary's assets and assumed all its liabilities pursuant to an agreement whereby it surrendered the shares for cancellation by the subsidiary. The difference between the cost of the shares and the net value of the subsidiary's assets when received, held to constitute a taxable gain to the corporation from a distribution in liquidation.

1Opinion of the Court

THE FRANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

France Co. v. Commissioner

Docket No. 64869.

United States Board of Tax Appeals

29 B.T.A. 661; 1934 BTA LEXIS 1502;

January 3, 1934, Promulgated

A corporation, owning by cash purchase all the shares of its subsidiary, received all the subsidiary's assets and assumed all its liabilities pursuant to an agreement whereby it surrendered the shares for cancellation by the subsidiary. The difference between the cost of the shares and the net value of the subsidiary's assets when received, held to constitute a taxable gain to…

2Cases cited1 opinion

  1. France Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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