John Glackner Realty Corp. v. Commissioner
United States Board of Tax Appeals
The petitioner on January 17, 1919, acquired four properties, each consisting of land and buildings, for which it gave all of its capital stock without allocating any shares to any one of the properties. The market value of two of the properties on the above date determined herein for the purpose of computing the gain derived upon their sale in 1921 and the allowable depreciation in 1920 and 1921.
1Opinion of the Court
*152OPINION.
Murdock:
The petitioner corporation having acquired the two properties in question after March 1, 1913, the profit or loss on their sale in 1921 is to be determined by the difference between the net selling price and the cost to the petitioner, properly depreciated to date of sale, and since the petitioner issued all of its capital stock for these two properties and two others, as a whole, the cost thereof *153to the petitioner was the market value of the properties at the date of acquisition. Rouse, Hempstone & Co., Inc., 7 B. T. A. 1018, 1024; and see Terrace Drive Co., 5 B. T. A. 1161.…
2Cited by7 opinions
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