Summary

Portrait of Hugo Black Hugo Black Commissioner of Internal Revenue v…

When the Senior Investment Corporation was organized Fisher and his wife paid for their shares of stock with securities which had cost them $14,500,000 but had by the date of organization acquired a market value of $88,000,000. To show that the corporation had a deficit and that consequently the distribution of General Motors stock was not from 'earnings or profits,' the taxpayers used the corporation's computation based on the $88,000,000 rather than the $14,500,000 figure.
Source: Wikisource

Portrait of Hugo Black Hugo Black Commissioner of Internal Revenue v…

Since Section 112 of the Revenue Act of 1934, 26 U.S.C.A. Int.Rev.Acts, page 692, did not tax the gain resulting from transfers of property to a corporation in exchange for stock in that corporation, it is obvious that rejection of the Commissioner's contention would result in permitting the Section 112 exemption to be used as a device for evading taxes Congress intended to impose on many gains actually realized from sales of property.
Source: Wikisource

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