Eaton v. Commissioner
United States Board of Tax Appeals
1. Petitioner, through a partnership of which he was a member, agreed to purchase from the stockholders of a corporation such shares of stock as should be offered within a certain period at $60 per share, although the market value of such shares was only $54. The agreement provided that he should receive 12,500 shares of the same kind of stock as compensation for undertaking and carrying out the purchase.
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1. Petitioner, through a partnership of which he was a member, agreed to purchase from the stockholders of a corporation such shares of stock as should be offered within a certain period at $60 per share, although the market value of such shares was only $54. The agreement provided that he should receive 12,500 shares of the same kind of stock as compensation for undertaking and carrying out the purchase. He purchased 79,687 shares and received the 12,500 shares, thus acquiring a total of 92,187 shares. The Commissioner added to his gross income the fair market value of the 12,500 shares.…
1Opinion of the Court
OPINION.
Meblott :
The Commissioner made several additions to the net income shown by petitioner’s return for the year 1929 and determined a deficiency in his income tax for said year in the amount of $157,-882.69. Some of the additions are conceded to have been made properly. The petition alleges that the respondent (Commissioner] erred: (1) in increasing petitioner’s taxable income by the addition of $427,343.75 representing the market value on December 3, 1929, of 12,500 shares of Central Alloy Steel Corporation common stock acquired by petitioner under the circumstances hereinafter related;…
2Cases cited4 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Shwab v. DoyleSupreme Court of the United States · 1922
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
3Cited by11 opinions
- Burr Oaks Corp. v. CommissionerUnited States Tax Court · 1965
- Jefferson Memorial Gardens, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Flannery v. United StatesDistrict Court, D. Maryland · 1938
- Davey Co. v. CommissionerUnited States Tax Court · 1959
- Marsan Realty Corp. v. CommissionerUnited States Tax Court · 1963
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