Ambassador Petroleum Co. v. Commissioner
United States Board of Tax Appeals
1. BASIS FOR GAIN OR LOSS - COST OF PROPERTY ACQUIRED FOR STOCK AND CASH. - Where a corporation issues its capital stock for property plus some cash, the cost of the property to the corporation is the fair market value of the stock plus the cash paid. Seymour Mfg.
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1. BASIS FOR GAIN OR LOSS - COST OF PROPERTY ACQUIRED FOR STOCK AND CASH. - Where a corporation issues its capital stock for property plus some cash, the cost of the property to the corporation is the fair market value of the stock plus the cash paid. Seymour Mfg. Co.,19 B.T.A. 1280, followed. 2. BASIC DATE FOR VALUING STOCK. - Where a corporation agrees in 1920 to issue its capital stock in part payment for property but does not actually issue the stock until 1923, the basic date for valuing the stock to determine the cost of the property is in 1920 when the obligation to issue the stock was…
1Opinion of the Court
AMBASSADOR PETROLEUM COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ambassador Petroleum Co. v. Commissioner
Docket No. 40039.
United States Board of Tax Appeals
28 B.T.A. 868; 1933 BTA LEXIS 1058;
August 8, 1933, Promulgated
1. BASIS FOR GAIN OR LOSS - COST OF PROPERTY ACQUIRED FOR STOCK AND CASH. - Where a corporation issues its capital stock for property plus some cash, the cost of the property to the corporation is the fair market value of the stock plus the cash paid. Seymour Mfg. Co.,19 B.T.A. 1280, followed.
2. BASIC DATE FOR VALUING STOCK. - Where a corporation agrees…
2Cases cited9 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
- United States v. Dakota-Montana Oil Co.Supreme Court of the United States · 1933
- Mead Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Ambassador Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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