Pinellas Ice & Cold Storage Co. v. Commissioner
United States Supreme Court
287 U.S. 462 (1933)
- Written by Daniel Clark, JD
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.)
What to do next…
Here's why 815,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.