Bancitaly Corp. v. Commissioner
United States Board of Tax Appeals
1. In the situation here obtaining, where stock was acquired en bloc and subsequently sold in lots or parcels, gain or loss will be computed separately on each sale and not deferred until the entire cost of the stock is recovered. 2. In a nontaxable transaction petitioner exchanged stock in various corporations and cash for stock and stock subscription warrants in other corporations and thereafter exchanged the subscription scription warrants and cash for additional shares.
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1. In the situation here obtaining, where stock was acquired en bloc and subsequently sold in lots or parcels, gain or loss will be computed separately on each sale and not deferred until the entire cost of the stock is recovered. 2. In a nontaxable transaction petitioner exchanged stock in various corporations and cash for stock and stock subscription warrants in other corporations and thereafter exchanged the subscription scription warrants and cash for additional shares. Held, upon the sale of new shares the cost of the securities received in exchange should be apportioned between the new…
1Opinion of the Court
BANCITALY CORPORATION, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bancitaly Corp. v. Commissioner
Docket Nos. 59674, 59461, 59462, 59464, 59466, 59491-59493.
United States Board of Tax Appeals
34 B.T.A. 494; 1936 BTA LEXIS 691;
April 30, 1936, Promulgated
1. In the situation here obtaining, where stock was acquired en bloc and subsequently sold in lots or parcels, gain or loss will be computed separately on each sale and not deferred until the entire cost of the stock is recovered.
2. In a nontaxable transaction petitioner exchanged stock in various corporations and cash…
2Cases cited8 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Burnet v. LoganSupreme Court of the United States · 1931
- Weiss v. StearnSupreme Court of the United States · 1924
- Ward v. CommissionerUnited States Board of Tax Appeals · 1934
- Von Gunten v. CommissionerUnited States Board of Tax Appeals · 1933
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