Orvilletta, Inc. v. Commissioner
United States Board of Tax Appeals
Petitioners purchased stock in the Equitable Trust Co. and Equitable Corporation. This stock was later exchanged for units of Chase Bank and Chase Securities stock. During the taxable year petitioners sold their Chase Bank stock and claimed a loss. Held, that, since no cost bases can be apportioned to the separate stocks, no loss can be taken until there is a disposition of the whole unit. Barber Securities Corporation,45 B.T.A. 521, followed.
1Opinion of the Court
opinion. •
Hill:
These proceedings are for a redeterminati'on of income tax deficiencies for the calendar year 1936 in .the amounts of $459.87 and $2,664.26 determined by the respondent against Orvilletta, Inc., and Walkpete, Inc., respectively. The proceedings were .consolidated for hearing and opinion. ' ' " . “
' The only issue is.whether or not petitioners arte entitled to a loss deduction upon the sale of stock in the Chase National Bank, hereinafter referred to as the Chase Bank. The answer depends upon whether the stock of the Chase Bank and Amerex Holding Corporation (formerly Chase…
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