Wheeler v. Commissioner
United States Board of Tax Appeals
Stock in two corporations was exchanged in a nontaxable transaction for stock in a third corporation and a portion of such stock of the third corporation, not identified as representing any particular shares of the two corporations, was sold at a profit.
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Stock in two corporations was exchanged in a nontaxable transaction for stock in a third corporation and a portion of such stock of the third corporation, not identified as representing any particular shares of the two corporations, was sold at a profit. Held, the cost of the stock in the two corporations should be allocated equally to all the shares of the third corporation for which exchanged for the purpose of computing gain from the sale of part of such shares of the latter corporation, in accordance with the rule laid down in Christian W. Von Gunten,28 B.T.A. 702; affd., 76 Fed.(2d) 670…
1Opinion of the Court
P. L. WHEELER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Wheeler v. Commissioner
Docket No. 69028.
United States Board of Tax Appeals
32 B.T.A. 917; 1935 BTA LEXIS 873;
July 10, 1935, Promulgated
Stock in two corporations was exchanged in a nontaxable transaction for stock in a third corporation and a portion of such stock of the third corporation, not identified as representing any particular shares of the two corporations, was sold at a profit. Held, the cost of the stock in the two corporations should be allocated equally to all the shares of the third corporation for which…
2Cases cited4 opinions
- Von Gunten v. CommissionerUnited States Board of Tax Appeals · 1933
- Oliver v. CommissionerUnited States Board of Tax Appeals · 1934
- Fuller v. CommissionerUnited States Board of Tax Appeals · 1934
- Wheeler v. CommissionerUnited States Board of Tax Appeals · 1935