W. C. Langley & Co. v. Commissioner
United States Board of Tax Appeals
Where a seat on the New York Stock Exchange is received by a partnership at an agreed valuation as the partner's capital contribution and it is sold at a loss in 1917, the partnership may deduct such loss in computing its taxable income.
1Opinion of the Court
*200OPINION.
Green:
The Commissioner contends that a partnership can have no interest in a seat on the New York Stock Exchange.
In the case of O'Dell v. Boyden, 150 Fed. 731, the Circuit Court of Appeals, Sixth Circuit, had before it a very similar set of facts. A partner, the legal owner of a seat on the New York Stock Exchange, sold to the partnership a one-fourth interest in the seat and contributed the remainder thereof to the partnership as his proportion of its capital. The partnership was declared a bankrupt and the trustee took possession of and sold the partnership’s beneficial interest in…
2Cases cited10 opinions
- Massie v. WattsSupreme Court of the United States · 1810
- Sparhawk v. YerkesSupreme Court of the United States · 1891
- Hyde v. WoodsSupreme Court of the United States · 1877
- Ager v. MurraySupreme Court of the United States · 1882
- Page v. EdmundsSupreme Court of the United States · 1903
5 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Archbald v. CommissionerUnited States Board of Tax Appeals · 1933
- W. C. Langley & Co. v. CommissionerUnited States Board of Tax Appeals · 1925