Legal Opinion

Coon Run Fuel Co. v. Commissioner

United States Tax Court

Decided April 21, 1953No. Docket No. 37297Published

Gain or Loss -- Basis -- Prior Owner -- Section 112 (b) (4), (5). -- Where one corporation permanently lost all of its properties through a sale to the state for delinquent taxes and another corporation acquired those properties by purchase from the state owners, the basis of the first corporate owner does not carry over to the other corporation.

1Opinion of the Court

Coon Run Fuel Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Coon Run Fuel Co. v. Commissioner

Docket No. 37297

United States Tax Court

20 T.C. 122; 1953 U.S. Tax Ct. LEXIS 188;

April 21, 1953, Promulgated

Decision will be entered for the respondent.

Gain or Loss -- Basis -- Prior Owner -- Section 112 (b) (4), (5). -- Where one corporation permanently lost all of its properties through a sale to the state for delinquent taxes and another corporation acquired those properties by purchase from the state owners, the basis of the first corporate owner does not carry over to the…

2Cases cited6 opinions

  1. Helvering v. HammelSupreme Court of the United States · 1941
  2. Helvering v. Nebraska Bridge Supply & Lumber Co.Supreme Court of the United States · 1941
  3. McCarty v. Cripe, Collector of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
  4. Adwood Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
  5. Adwood Corp. v. CommissionerUnited States Tax Court · 1950

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