Fesler v. Commissioner

Siefkin:

This is a proceeding for the redetermination of a deficiency in income tax for the calendar year 1923 in the amount of $61,401.86. The only question is whether certain securities received on an exchange in 1923 had “ a readily realizable market value ” within the meaning of section 202 (c) of the Revenue Act of 1921, which provides:(c) For the purposes of this title, on an exchange of property, real, personal or mixed, for any other such property, no gain or loss shall be recognized unless the property received in exchange has a readily realizable market value; * * *

The petitioner is…