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Paulsen Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Jan 08, 1985
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U.S. 131 (1985) U.S. Supreme Court Paulsen v. CommissionerSearch
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U.S. 131 (1985) Paulsen v. CommissionerSearch
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and the retained interest must represent a substantial part of the value of the thing transferred, Helvering v. MinnesotaSearch
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U. S. 140 -142. (c) To characterize petitioners' Citizen shares as debt does not conflict with Tcherepnin v. KnightSearch
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Southwest Natural Gas Co. v. CommissionerSearch
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F.2d 332, 334 (CA5), cert. denied, 342 U.S. 860 (1951) ( quoting Commissioner v. Gilmore'sSearch
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organization must continue in a meaningful fashion in the reorganized enterprise. Pinellas Ice & Cold Storage Co. v. CommissionerSearch
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Helvering v. MinnesotaSearch
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Tea Co., 296 U. S. 378 , 296 U. S. 385 (1935). Compare LeTulle v. ScofieldSearch
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no retained property interest where transferor received transferee's bonds), with John A. Nelson Co. v. HelveringSearch
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that the Commissioner's position had been uniformly rejected by the courts. Following Capital Savings and Loan Assn. v. UnitedSearch
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West Side Federal Savings and Loan Assn. v. UnitedSearch
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Everett v. UnitedSearch
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The ownership interest of the Citizens shareholders is closer to that of the secured bondholders in LeTulle v. ScofieldSearch
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U.S. at 308 U. S. 420 -421, than to that of the preferred stockholders in John A. Nelson Co. v. HelveringSearch
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of the value of the Commerce stock formerly held by petitioners. See Southwest Natural Gas Co. v. CommissionerSearch
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the characterization of their mutual association shares as debt conflicts with this Court's decision in Tcherepnin v. KnightSearch
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a)(10) of the Securities Exchange Act of 1934. Cf. Marine Bank v. WeaverSearch
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Wisconsin Bankers Assn. v. RobertsonSearch
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Capital Savings and Loan Assn. v. UnitedSearch
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at 469 U. S. 136 . The Treasury Regulations, codifying the requirements of this Court's decisions in Gregory v. HelveringSearch
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U. S. 465 (1935), and Pinellas Ice & Cold Storage Co. v. CommissionerSearch
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business that represents a substantial part of the value of the property transferred. Pinellas Ice & Cold Storage Co. v. CommissionerSearch
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to qualify as a reorganization. Id. at 287 U. S. 470 . Three Terms later, in Helvering v. MinnesotaSearch
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assets were exchanged for 38 percent nonvoting and redeemable preferred stock and 62 percent cash. John A. Nelson Co. v. HelveringSearch
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s bonds was held to make the bondholders merely creditors rather than proprietary owners of the business. LeTulle v. ScofieldSearch
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by petitioners here is more weighty than that obtained by the nonvoting, preferred shareholders in John A. Nelson Co. v. HelveringSearch
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found ownership of non voting preferred stock to provide a sufficient proprietary interest. John A. Nelson Co. v. HelveringSearch
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U.S. Supreme Court Paulsen v. CommissionerSearch
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Commissioner v. Gilmore'sSearch
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Pinellas Ice & Cold Storage Co. v. CommissionerSearch
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Compare LeTulle v. ScofieldSearch
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John A. Nelson Co. v. HelveringSearch
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Following Capital Savings and Loan Assn. v. UnitedSearch
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Savings v. BowersSearch
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See Southwest Natural Gas Co. v. CommissionerSearch
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Cf. Marine Bank v. WeaverSearch
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and Pinellas Ice & Cold Storage Co. v. CommissionerSearch
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