Pulfer v. Commissioner
United States Board of Tax Appeals
Petitioner, the owner of 200 shares of stock of the A corporation, entered into an agreement with the B corporation, which already owned 1,220 shares of A corporation's stock, whereby petitioner and two other individuals would exchange 556 shares of A stock for 3,336 shares of B stock. By virtue of the exchange B became owner of all the outstanding stock of A, with the exception of the qualifying shares.
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Petitioner, the owner of 200 shares of stock of the A corporation, entered into an agreement with the B corporation, which already owned 1,220 shares of A corporation's stock, whereby petitioner and two other individuals would exchange 556 shares of A stock for 3,336 shares of B stock. By virtue of the exchange B became owner of all the outstanding stock of A, with the exception of the qualifying shares. No proof was offered to show that B's acquisition of its original holding of 1,220 shares of A stock was solely in exchange for its voting stock. Held, the exchange of petitioner's A…
1Opinion of the Court
ROBERT A. PULFER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Pulfer v. Commissioner
Docket No. 97262.
United States Board of Tax Appeals
43 B.T.A. 677; 1941 BTA LEXIS 1465;
February 19, 1941, Promulgated
Petitioner, the owner of 200 shares of stock of the A corporation, entered into an agreement with the B corporation, which already owned 1,220 shares of A corporation's stock, whereby petitioner and two other individuals would exchange 556 shares of A stock for 3,336 shares of B stock. By virtue of the exchange B became owner of all the outstanding stock of A, with the exception…
2Cases cited9 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Weiss v. WeinerSupreme Court of the United States · 1929
- Agar v. OrdaNew York Court of Appeals · 1934
- Agar v. OrdaNew York Supreme Court · 1932
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