Wright v. Commissioner
United States Board of Tax Appeals
The petitioner in 1922, in accordance with a plan of the bankers to manage the company in which he was a stockholder, surrendered 131 shares of stock. The stock was given to the new manager. Held the petitioner is entitled to deduct from gross income for 1922 the cost of the stock surrendered.
1Opinion of the Court
*472OFINIOH.
ARTjndell:
The only question to be determined in this proceeding is whether there was a closed transaction in 1922 with respect to 131 shares of stock in the American Hominy Co. which petitioner surrendered in that year to the bankers of the company, and which in turn the bankers paid over to a new company manager of their selection. If the stock had been merely surrendered to the company so that the proportionate representation of stockholders re*473mained the same, a different question would be presented (see Edith Scoville, 18 B. T. A. 261), but it is clear from the stipulated facts…
2Cited by17 opinions
- Downer v. CommissionerUnited States Tax Court · 1967
- Tilford v. CommissionerUnited States Tax Court · 1980
- Frantz v. CommissionerUnited States Tax Court · 1984
- Leroy Frantz, Jr. And Sheila Frantz v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Bed Rock Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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