Orange Sec. Corp. v. Commissioner
United States Board of Tax Appeals
1. Petitioner is the transferee of one Giles, who in the year 1926 sold certain real property with a basis of $5,720, taking in exchange therefor notes with a face value of $98,700. Giles reported no gain on this transaction. These notes, transferred to petitioner in a tax-free exchange in 1930, were settled by the debtor during the taxable year for $80,000. Held, petitioner must use as basis in computing gain the basis of the property to its transferor.
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1. Petitioner is the transferee of one Giles, who in the year 1926 sold certain real property with a basis of $5,720, taking in exchange therefor notes with a face value of $98,700. Giles reported no gain on this transaction. These notes, transferred to petitioner in a tax-free exchange in 1930, were settled by the debtor during the taxable year for $80,000. Held, petitioner must use as basis in computing gain the basis of the property to its transferor. Gain so computed is the difference between $5,720 and $80,000. 2. Payment of $5,000 extra compensation to petitioner's general manager for…
1Opinion of the Court
ORANGE SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Orange Sec. Corp. v. Commissioner
Docket No. 104499.
United States Board of Tax Appeals
45 B.T.A. 24; 1941 BTA LEXIS 1192;
September 4, 1941, Promulgated
1. Petitioner is the transferee of one Giles, who in the year 1926 sold certain real property with a basis of $5,720, taking in exchange therefor notes with a face value of $98,700. Giles reported no gain on this transaction. These notes, transferred to petitioner in a tax-free exchange in 1930, were settled by the debtor during the taxable year for…
2Cases cited13 opinions
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Prendergast v. CommissionerUnited States Board of Tax Appeals · 1931
- Alamo Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1937
- Automatic Sprinkler Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Orange Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1941
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