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Pinellas Ice & Cold Storage Co. v. Commissioner

287 U.S. 462 (1933)

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Pinellas Ice & Cold Storage Co. v. Commissioner

United States Supreme Court

287 U.S. 462 (1933)

Facts

Pinnellas Ice & Cold Storage Company (Pinnellas) (plaintiff) transferred substantially all of its assets to another corporation in exchange for cash, some of which was to be paid up front and some of which would be paid in deferred installments. The purchasing corporation also issued notes to Pinnellas paying interest on the deferred installments. Pinnellas treated the transaction as a tax-free reorganization. The Internal Revenue Service (IRS) treated the transaction as a taxable sale of assets and assessed taxable gain to Pinnellas. The United States Board of Tax Appeals and the Circuit Court of Appeals for the Fifth Circuit upheld the IRS’s determination. Pinnellas appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (McReynolds, J.)

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