Lloyd v. Commissioner
United States Board of Tax Appeals
An agreement whereby an individual promised and agreed to make future payments to the petitioner during the petitioner's life, made in consideration of the transfer by the petitioner to such individual of certain shares of stock, had no fair market value when received by the petitioner, and, as the cash payments received during the year in which the agreement was made did not exceed the basis of the stock, the petitioner realized no taxable gain from the transaction in that…
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An agreement whereby an individual promised and agreed to make future payments to the petitioner during the petitioner's life, made in consideration of the transfer by the petitioner to such individual of certain shares of stock, had no fair market value when received by the petitioner, and, as the cash payments received during the year in which the agreement was made did not exceed the basis of the stock, the petitioner realized no taxable gain from the transaction in that year.
1Opinion of the Court
*904OPINION.
Murdock :
The petitioner completely disposed of 2,499 shares of Harold Lloyd Corporation stock in 1930. The question is whether he realized from the transaction any gain taxable in 1930. Section 111 of the Revenue Act of 1928 provides that the gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the basis. The basis here has been stipulated. The amount realized is defined in section 111 (c) as “ the sum of any money received plus the fair market value of the property (other than money) received.” The petitioner received no money…
2Cases cited3 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Burnet v. LoganSupreme Court of the United States · 1931
- Simpson v. United StatesSupreme Court of the United States · 1920
3Cited by28 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- Lazarus v. CommissionerUnited States Tax Court · 1972
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- La Fargue v. CommissionerUnited States Tax Court · 1979
- Estate of Bell v. CommissionerUnited States Tax Court · 1973
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