Madison Fund, Inc. v. Commissioner
United States Tax Court
Held: That the net amount received by petitioner in 1947 in settlement of two stockholders' derivative suits against the Pennsylvania Railroad Co., for recovery of losses resulting from breach of a fiduciary relationship in causing improper investments of petitioner's funds, is properly allocable among the investments complained of in the suits, and that the amount so allocated to investments sold in the years 1952 through 1960 serves to reduce the bases thereof for the…
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Held: That the net amount received by petitioner in 1947 in settlement of two stockholders' derivative suits against the Pennsylvania Railroad Co., for recovery of losses resulting from breach of a fiduciary relationship in causing improper investments of petitioner's funds, is properly allocable among the investments complained of in the suits, and that the amount so allocated to investments sold in the years 1952 through 1960 serves to reduce the bases thereof for the purpose of determining gain or loss upon the sales in those years. The method of allocation determined.
1Opinion of the Court
Madison Fund, Inc. (Formerly the Pennroad Corporation), Petitioner, v. Commissioner of Internal Revenue, Respondent
Madison Fund, Inc. v. Commissioner
Docket Nos. 93718, 4194-62
United States Tax Court
43 T.C. 215; 1964 U.S. Tax Ct. LEXIS 15;
November 23, 1964, Filed November 23, 1964, Filed
Decisions will be entered under Rule 50.
Held: That the net amount received by petitioner in 1947 in settlement of two stockholders' derivative suits against the Pennsylvania Railroad Co., for recovery of losses resulting from breach of a fiduciary relationship in causing improper investments of petitioner's…
2Cases cited16 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Helvering v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1942
- Overfield v. Pennroad CorporationCourt of Appeals for the Third Circuit · 1944
- United Mercantile Agencies, Inc. v. CommissionerUnited States Tax Court · 1955
- F. W. Drybrough v. Commissioner of Internal Revenue, L. N. Simpson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
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