Vale v. Commissioner
United States Board of Tax Appeals
1. In 1925 the petitioner sold certain stock and bonds received by her upon a distribution in 1920 or a subsequent year of a portion of the assets of a trust estate in which in 1910 she had acquired a one-sixth residuary interest in the corpus and the income. Such interest was, under the will, charged with its proportional part of certain stated periodical payments to be made during the lives of certain other beneficiaries.
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1. In 1925 the petitioner sold certain stock and bonds received by her upon a distribution in 1920 or a subsequent year of a portion of the assets of a trust estate in which in 1910 she had acquired a one-sixth residuary interest in the corpus and the income. Such interest was, under the will, charged with its proportional part of certain stated periodical payments to be made during the lives of certain other beneficiaries. Held, that in determining the gain or loss from the sale of the stock and bonds their value on the basic date is to be reduced by a proportional part of the value of the…
1Opinion of the Court
OPINION.
Trammell:
This proceeding is for the redetermination of deficiencies in income tax of $6,888.36, $539.72, and $296173 for 1925, 1926, and 1927, respectively. The matters put in controversy by the petition as amended are the correctness of the respondent’s action (1) in using the March 1, 1913, value in determining the amount of a loss sustained in 1925 on the sale of bonds of Manitou & Pikes Peak Railway Co.; (2) in refusing to allow as deductions for 1925 as losses the amounts of $5,234.50 and $4,478.41 alleged to have been *1352sustained on tbe sale of shares of stock and of notes,…
2Cases cited1 opinion
- Huggett v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by2 opinions
- Slack v. CommissionerUnited States Board of Tax Appeals · 1937
- Vale v. CommissionerUnited States Board of Tax Appeals · 1934