First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Opinions respecting values of properties, although expressed by those in a position to know, in the absence of supporting data upon which they are based, will not be accepted in substitution for proof of positive facts. Tracy v. Commissioner, 53 Fed.(2d) 575. 2. Cost to be used for determining gain or loss on corporate stock acquired from a converted investment made prior to March 1, 1913, determined.
1Opinion of the Court
OPINION.
Lansdon :
The appeals consolidated in these proceedings challenge income taxes determined for the years 1927, 1928, and 1929 in the respective amounts of $2,812.50, $1,875, and $1,456.52.
The only dispute between the parties relates to the March 1, 1913, value of certain corporation stock sold by the petitioner and upon which taxable gain in each year is at issue.
During each of the taxable years the petitioner sold a certain number of shares of the common stock of the Southeastern Power & Light Co., successor to a Canadian corporation known as the Alabama Traction, Light & Power Co.,…
2Cases cited3 opinions
- Austin v. CommissionerUnited States Board of Tax Appeals · 1928
- Hunt v. CommissionerUnited States Board of Tax Appeals · 1928
- Sturgess v. CommissionerUnited States Board of Tax Appeals · 1925
3Cited by2 opinions
- Buck v. United StatesDistrict Court, D. Delaware · 1957
- First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933