Commonwealth Improv. Co. v. Commissioner
United States Board of Tax Appeals
1. The original cost of stock, with respect to which stock rights have been received and exercised, must be adjusted to give effect to the acquisition of the new stock in determining the basis for computing gain or loss upon the sale of a portion of such stock.
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1. The original cost of stock, with respect to which stock rights have been received and exercised, must be adjusted to give effect to the acquisition of the new stock in determining the basis for computing gain or loss upon the sale of a portion of such stock. Miles v. Safe Deposit Co.,259 U.S. 247, and Frederick Ayer,6 B.T.A. 152; affd., 25 Fed.(2d) 534, followed. 2. The sale of securities by a corporation to its sole stockholder at a price in excess of cost and March 1, 1913, value results in taxable gain.
1Opinion of the Court
COMMONWEALTH IMPROVEMENT CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Commonwealth Improv. Co. v. Commissioner
Docket No. 24959.
United States Board of Tax Appeals
20 B.T.A. 1189; 1930 BTA LEXIS 1958;
October 8, 1930, Promulgated
1. The original cost of stock, with respect to which stock rights have been received and exercised, must be adjusted to give effect to the acquisition of the new stock in determining the basis for computing gain or loss upon the sale of a portion of such stock. Miles v. Safe Deposit Co.,259 U.S. 247, and Frederick Ayer,6 B.T.A. 152; affd., 25 Fed.(2d)…
2Cases cited3 opinions
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Ayer v. CommissionerUnited States Board of Tax Appeals · 1927
- Commonwealth Improv. Co. v. CommissionerUnited States Board of Tax Appeals · 1930