Appeal of United States Trust Co.
This text of 1 B.T.A. 901 (Appeal of United States Trust Co.) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
[903]*903OPINION.
The taxpayer contends that the situation presented for our consideration is a simple one, consisting only of a purchase of [904]*904shares of stock for cash, the receipt of a less amount upon surrender of the stock, and a consequent deductible loss. The transaction thus presented is so simple that it is confounding.
Before March 30, 1918, the taxpayer owned directly, or controlled, all of the stock of the Company, and, therefore, the Company was an affiliated subsidiary of the taxpayer. The liquidation of the Company did not in any way produce a loss which the taxpayer would be allowed to deduct under section 234 (a) of the Revenue Act of 1918.
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