Peavey Paper Mills (Inc.) v. Commissioner
United States Tax Court
Held: That respondent has failed to prove that the fair market value of 147 of petitioner's 300 authorized shares was, on July 16, 1951, worth less than the stated contract price for such shares. Respondent has therefore not proved the applicability of section 275(c), I.R.C. 1939, and the year 1951 is thus barred by the statute of limitations.
1Opinion of the Court
Peavey Paper Mills (Inc.) v. Commissioner.
Peavey Paper Mills (Inc.) v. Commissioner
Docket No. 78859.
United States Tax Court
T.C. Memo 1960-237; 1960 Tax Ct. Memo LEXIS 53; 19 T.C.M. (CCH) 1325; T.C.M. (RIA) 60237;
November 4, 1960
Held: That respondent has failed to prove that the fair market value of 147 of petitioner's 300 authorized shares was, on July 16, 1951, worth less than the stated contract price for such shares. Respondent has therefore not proved the applicability of section 275(c), I.R.C. 1939, and the year 1951 is thus barred by the statute of limitations.
John S. Best, Esq., 110 E.…
2Cases cited9 opinions
- Particelli v. Commissioner of Internal Revenue. Particelli's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- Ketler v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1952
- Fox River Paper Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1948
- Joseph Frank v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Evans v. CommissionerUnited States Board of Tax Appeals · 1934
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