Southwest Natural Gas Co. v. Commissioner

189 F.2d 332 (1951)

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Southwest Natural Gas Co. v. Commissioner

United States Court of Appeals for the Fifth Circuit

189 F.2d 332 (1951)

Facts

Southwest Natural Gas Company (Southwest) (plaintiff) merged with Peoples Gas & Fuel Corporation (Peoples). Southwest claimed the merger was a corporate reorganization. After the merger, the continuing interest in Peoples was less than 1 percent of the price paid by Southwest to acquire Peoples. The commissioner of the Internal Revenue Service (IRS) (defendant) determined that there was no continuity of interest in the transaction and thus the merger was a sale. Southwest filed a petition for review in the United States Tax Court.

Rule of Law

Issue

Holding and Reasoning (Russell, J.)

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