Society Brand Clothes, Inc. v. Commissioner
United States Tax Court
1. In connection with the settlement of an indebtedness in January 1934, petitioner received 24,000 shares of its own stock which, in the settlement made, were subject to a 10-year option. During January 1934, shares of the stock, unrestricted by any option, were sold at prices between $ 1 1/8 and $ 2 1/2 per share.
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1. In connection with the settlement of an indebtedness in January 1934, petitioner received 24,000 shares of its own stock which, in the settlement made, were subject to a 10-year option. During January 1934, shares of the stock, unrestricted by any option, were sold at prices between $ 1 1/8 and $ 2 1/2 per share. Under the terms of the option the stock was sold in December 1943. Held, the evidence shows that the stock, encumbered as it was by a 10-year option which compelled petitioner to hold the stock during the term of the option, had no fair market value at the time it was received in…
1Opinion of the Court
Society Brand Clothes, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Society Brand Clothes, Inc. v. Commissioner
Docket No. 28122
United States Tax Court
18 T.C. 304; 1952 U.S. Tax Ct. LEXIS 198;
May 13, 1952, Promulgated
Decision will be entered under Rule 50.
1. In connection with the settlement of an indebtedness in January 1934, petitioner received 24,000 shares of its own stock which, in the settlement made, were subject to a 10-year option. During January 1934, shares of the stock, unrestricted by any option, were sold at prices between $ 1 1/8 and $ 2 1/2 per share. Under…
2Cases cited7 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Burnet v. LoganSupreme Court of the United States · 1931
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Gould Securities Co. v. United StatesCourt of Appeals for the Second Circuit · 1938
- United States v. TillinghastCourt of Appeals for the First Circuit · 1934
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