Snyder v. Commissioner
United States Board of Tax Appeals
Where the petitioner, buying and selling stocks on margin with no shares earmarked by having certificates issued in his own name, fails to show which of several lots of stock he sold and which he retained, the respondent's determination that he sold those first acquired is approved.
1Opinion of the Court
*780OPINION.
Black :
The respondent made explanation of the change made in computing petitioner’s income, as follows:
In accordance with Article 39, Regulations 69, when shares of stock in a corporation are sold from lots purchased at different dates and at different prices and the identity of the lots cannot be determined, the stock sold shall be charged *781against the earliest purchases of such stock. The increase in the profit on sale of stock is the result of applying the cost of the earliest purchases against the selling price.
In contradiction to the method used by respondent in his determination,…
2Cited by13 opinions
- Von Gunten v. CommissionerUnited States Board of Tax Appeals · 1933
- Mickler Holding Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Heinz v. CommissionerUnited States Board of Tax Appeals · 1933
- Oliver v. CommissionerUnited States Board of Tax Appeals · 1934
- Snyder v. CommissionerUnited States Board of Tax Appeals · 1933
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