French Dry Cleaning Co. v. Commissioner of Internal Revenue

FOSTER, Circuit Judge.

On January 16, 1928, petitioner transferred substantially all its assets to Atlanta Laundries, Inc., a Delaware corporation, organized for the purpose of consolidating and acquiring the business and assets of petitioner and ten other laundries and dry cleaning establishments operating in Atlanta, Ga. Petitioner received $305,331.18 cash, 3,025 shares of preferred stock, and 7,652-1/£j shares of common stock of the new corporation, both having no par value. Petitioner returned no taxable income for 1928 and paid no tax. The Commissioner determined a deficiency of…