OPINION.
STERNHAGEN, Judge:
The Commissioner determined a deficiency of $10,562.78 in withholding income tax for 1939, holding that the exchange in 1939 by petitioner's preferred shareholders of preferred shares for its debentures was taxable to them as a dividend to the extent of earnings and profits. The petitioner contends that such exchange was a recapitalization pursuant to a plan of reorganization, gain from which is not recognized. The facts...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.