Matheson v. Commissioner
United States Board of Tax Appeals
The petitioner was bequeathed the cash sum of $500,000 in the will of his father, which was credited to him on the books of the estate on May 15, 1930, the date of the decedent's death. On August 27, 1930, the petitioner agreed to purchase certain securities from the estate, with a portion of his legacy, at the fair market values of said securities as of May 15, 1930, such amounts aggregating $19,500 more than the fair market values on the date of purchase.
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The petitioner was bequeathed the cash sum of $500,000 in the will of his father, which was credited to him on the books of the estate on May 15, 1930, the date of the decedent's death. On August 27, 1930, the petitioner agreed to purchase certain securities from the estate, with a portion of his legacy, at the fair market values of said securities as of May 15, 1930, such amounts aggregating $19,500 more than the fair market values on the date of purchase. Held, the actual "cost" of such securities and not the fair market values thereof at the date of purchase should be used in the…
1Opinion of the Court
OPINION.
MoRRis:
The respondent having determined a deficiency in income tax of $7,524.82 for the calendar year 1930, the petitioner brings this proceeding for the redetermination thereof, alleging error in such determination by reason of the use of an aggregate of $111,200 as the “ cost ” basis for the computation of gain or loss upon sale thereof; his ruling that the purchase and sale of said stocks did not constitute a transaction entered into for profit; that certain items were not deductible as bad debts; and his failure to permit the deduction of the sum of $8,000 representing the cost of…
2Cited by13 opinions
- Solitron Devices, Inc. v. CommissionerUnited States Tax Court · 1983
- Jordan v. CommissionerUnited States Tax Court · 1973
- Early v. CommissionerUnited States Tax Court · 1969
- White Farm Equipment Co. v. CommissionerUnited States Tax Court · 1973
- Johnson v. CommissionerUnited States Tax Court · 1962
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