Legal Opinion

W. G. Maguire & Co. v. Commissioner

United States Tax Court

Decided April 8, 1953No. Docket Nos. 36033, 36034, 36035Published

1. Mokan Corporation acquired Panhandle Eastern stock at a cost of $ 47.86 per share. During 1944, Mokan issued to its stockholders rights to buy Panhandle Eastern stock at $ 30 per share, and on the date the rights were issued the fair market value of each share was $ 40. During the period the rights were being exercised the value of the shares increased. Stockholders of Mokan, among whom were the petitioners, purchased 151,958 shares of the stock.

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1. Mokan Corporation acquired Panhandle Eastern stock at a cost of $ 47.86 per share. During 1944, Mokan issued to its stockholders rights to buy Panhandle Eastern stock at $ 30 per share, and on the date the rights were issued the fair market value of each share was $ 40. During the period the rights were being exercised the value of the shares increased. Stockholders of Mokan, among whom were the petitioners, purchased 151,958 shares of the stock. In computing Mokan's "earnings or profits" for the year 1944, the Commissioner would allow no deduction from net income based on the sale of the…

1Opinion of the Court

W. G. Maguire & Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent. William G. Maguire, Petitioner, v. Commissioner of Internal Revenue, Respondent. Marian L. Maguire, Petitioner, v. Commissioner of Internal Revenue, Respondent

W. G. Maguire & Co. v. Commissioner

Docket Nos. 36033, 36034, 36035

United States Tax Court

20 T.C. 20; 1953 U.S. Tax Ct. LEXIS 200;

April 8, 1953, Promulgated

Decisions will be entered under Rule 50.

1. Mokan Corporation acquired Panhandle Eastern stock at a cost of $ 47.86 per share. During 1944, Mokan issued to its stockholders rights to buy Panhandle…

2Cases cited11 opinions

  1. Palmer v. CommissionerSupreme Court of the United States · 1937
  2. R. D. Merrill Co. v. CommissionerUnited States Tax Court · 1945
  3. Young v. CommissionerUnited States Tax Court · 1945
  4. Stone v. ComissionerUnited States Tax Court · 1953
  5. Godley v. CommissionerUnited States Tax Court · 1953

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