Legal Opinion

Hoffer v. Commissioner

United States Board of Tax Appeals

Decided September 16, 1931No. Docket Nos. 33374, 33375PublishedCited by 8 opinions

1. The basic date for valuing stock received as part consideration upon the sale of property is the date when taxpayer is entitled to receive the stock and not the date the stock certificates were delivered to the vendor. 2. The fair market value of shares of stock determined.

1Opinion of the Court

*26OPINION.

Smith:

The first allegation of error raises issues relating to the basic value of four oil leases and the manner in which these leases were acquired. No proof as to the value of the leases was offered and the petitioners concede the correctness of the respondent’s affirmative allegation that, in computing the profit upon the sale of the leases, the Barnes lease had been erroneously valued at $30,225 instead of $30,000, as claimed by the petitioners and determined by the respondent. With this correction, the respondent’s determination of the value of the four leases is sustained.

The…

2Cases cited11 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Boom Co. v. PattersonSupreme Court of the United States · 1879
  3. United States v. Chandler-Dunbar Water Power Co.Supreme Court of the United States · 1913
  4. Richardson v. ShawSupreme Court of the United States · 1908
  5. Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930

6 more not listed; retrieve them via the Exa API.

3Cited by8 opinions

  1. Bankers Trust Co. v. United StatesUnited States Court of Claims · 1975
  2. Ambassador Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Ambassador Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Bonsall v. CommissionerUnited States Tax Court · 1962
  5. Guggenheim v. CommissionerUnited States Board of Tax Appeals · 1939

3 more not listed; retrieve them via the Exa API.

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