Legal Opinion

Dodge v. Commissioner

United States Board of Tax Appeals

Decided August 3, 1928No. Docket No. 4640Published

1. A valuation of stock as of March 1, 1913, made by the Commissioner's predecessor in office at the request of a taxpayer before any sale had been consummated, does not preclude the Commissioner from placing a different valuation on the stock as of that date in determining tax liability resulting from the sale thereof.

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1. A valuation of stock as of March 1, 1913, made by the Commissioner's predecessor in office at the request of a taxpayer before any sale had been consummated, does not preclude the Commissioner from placing a different valuation on the stock as of that date in determining tax liability resulting from the sale thereof. James Couzens,11 B.T.A. 1040; Rosetta V. Hauss,12 B.T.A. 755. 2. Upon the authority of the cases cited above, held that shares of stock of the Ford Motor Co. sold by the taxpayer had a fair market value on March 1, 1913, of $10,000 per share. 3. A waiver of the time prescribed…

1Opinion of the Court

ESTATE OF JOHN F. DODGE, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Dodge v. Commissioner

Docket No. 4640.

United States Board of Tax Appeals

13 B.T.A. 201; 1928 BTA LEXIS 3292;

August 3, 1928, Promulgated

1. A valuation of stock as of March 1, 1913, made by the Commissioner's predecessor in office at the request of a taxpayer before any sale had been consummated, does not preclude the Commissioner from placing a different valuation on the stock as of that date in determining tax liability resulting from the sale thereof. James Couzens,11 B.T.A. 1040; Rosetta V. Hauss,12…

2Cases cited2 opinions

  1. Estate of Dodge v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Dodge v. CommissionerUnited States Board of Tax Appeals · 1928

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