Axton v. Commissioner
United States Board of Tax Appeals
1. Where two different kinds of stock are received in exchange for a third kind of stock, and it appears that there is no satisfactory basis of comparison of the values of the two types of new shares received, no allocation of the old basis need be made. 2. Book value, in this particular case, is an unsatisfactory basis of comparison, and does not afford a satisfactory means of dividing the old basis between the two types of new shares.
1Opinion of the Court
EDWIN D. AXTON, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Axton v. Commissioner
Docket Nos. 56160-56163, 56348, 56438-56442.
United States Board of Tax Appeals
32 B.T.A. 613; 1935 BTA LEXIS 924;
May 14, 1935, Promulgated
1. Where two different kinds of stock are received in exchange for a third kind of stock, and it appears that there is no satisfactory basis of comparison of the values of the two types of new shares received, no allocation of the old basis need be made.
2. Book value, in this particular case, is an unsatisfactory basis of comparison, and does not afford…
2Cases cited1 opinion
- Axton v. CommissionerUnited States Board of Tax Appeals · 1935