Ball v. Commissioner
United States Board of Tax Appeals
1. INCOME - APPORTIONMENT OF COST. - Held, that the evidence does not overcome the presumptive correctness of the Commissioner's determination that the total cost of common and preferred stock, purchased for a lump consideration, was allocable to the preferred stock alone. 2. GAIN OR LOSS. - Held, that an exchange of stock for stock as the result of a merger in 1915 constituted a reorganization within the meaning of section 203(h)(1)(A) of the 1926 Act, and was an exchange…
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1. INCOME - APPORTIONMENT OF COST. - Held, that the evidence does not overcome the presumptive correctness of the Commissioner's determination that the total cost of common and preferred stock, purchased for a lump consideration, was allocable to the preferred stock alone. 2. GAIN OR LOSS. - Held, that an exchange of stock for stock as the result of a merger in 1915 constituted a reorganization within the meaning of section 203(h)(1)(A) of the 1926 Act, and was an exchange such as described in section 203(b)(2), and that section 204(a)(6) is applicable for determining the basis for gain or…
1Opinion of the Court
PHILIP D. C. BALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ball v. Commissioner
Docket No. 40926.
United States Board of Tax Appeals
27 B.T.A. 388; 1932 BTA LEXIS 1072;
December 21, 1932, Promulgated
1. INCOME - APPORTIONMENT OF COST. - Held, that the evidence does not overcome the presumptive correctness of the Commissioner's determination that the total cost of common and preferred stock, purchased for a lump consideration, was allocable to the preferred stock alone.
2. GAIN OR LOSS. - Held, that an exchange of stock for stock as the result of a merger in 1915 constituted a…
2Cases cited1 opinion
- Ball v. CommissionerUnited States Board of Tax Appeals · 1932