(Download) "Choate v. Commissioner of Internal Revenue." by United States Court of Appeals for the Second Circuit # eBook PDF Kindle ePub Free
eBook details
- Title: Choate v. Commissioner of Internal Revenue.
- Author : United States Court of Appeals for the Second Circuit
- Release Date : January 24, 1942
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 66 KB
Description
This petition involves the petitioners liability for an asserted income tax deficiency of $2,789.45, imposed by reason of his receipt of stock purchase rights. The facts were stipulated before the Board, and were found by it as stipulated. The taxpayer owned 10,000 shares of the common stock of the Crane Company, an Illinois corporation, which had outstanding on May 1, 1937, 2,348,628 shares of common and 145,889 shares of seven percent cumulative preferred. In May, 1937, Cranes articles of incorporation were amended to authorize the issuance of 200,000 shares of five percent cumulative preferred, to be subject to the outstanding seven percent preferred. The new preferred was convertible into common stock at specified ratios varying from time to time. On May 28, 1937, the common stockholders, pro rata, were given the right to subscribe to the new preferred on or before June 17, 1937, at $100 a share (the par value) at the rate of one share of preferred to each twelve shares of common. Underwriters agreed with Crane to take, at par, any unsubscribed preferred.