Hagerman v. Commissioner
United States Board of Tax Appeals
Petitioner purchased in 1918, 1919, and 1931 at a unit cost certificates of bank stock, having thereon an endorsement entitling the registered holder thereof to share equally and ratably with all other holders of like certificates similarly endorsed, according to their several interests, in dividends or profits, and in case of dissolution, in the distribution of the capital, of another corporation, the Security Co. The endorsement provided that "the interest in the Security…
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Petitioner purchased in 1918, 1919, and 1931 at a unit cost certificates of bank stock, having thereon an endorsement entitling the registered holder thereof to share equally and ratably with all other holders of like certificates similarly endorsed, according to their several interests, in dividends or profits, and in case of dissolution, in the distribution of the capital, of another corporation, the Security Co. The endorsement provided that "the interest in the Security Company attached to any share of the Bank stock shall be alienable, only in connection with the transfer of such Bank…
1Opinion of the Court
*1164OPINION.
Disnex:
The issues presented for our determination are (1) whether it is practicable to apportion fairly to the declarations of interest sold by the petitioner a part of the unit cost of his stock in the Bank and in the Security Co., and (2) if so, what cost should be apportioned to such declarations of interest, otherwise designated herein Security Co. stock.
The petitioner contends that it is practicable to apportion fairly the cost of the units of Bank stock and Security Co. stock on the basis of their respective values at the dates of purchase (1) on the basis of the respective…
2Cases cited2 opinions
- Cosden Oil & Gas Co. v. MossSupreme Court of Oklahoma · 1928
- Desportes v. Southern Ry.Supreme Court of South Carolina · 1910
3Cited by8 opinions
- De Coppet v. HelveringCourt of Appeals for the Second Circuit · 1940
- Spreckels-Rosekrans Inv. Co. v. LewisCourt of Appeals for the Ninth Circuit · 1945
- Adams v. CommissionerUnited States Tax Court · 1944
- Barber Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1941
- De Coppet v. CommissionerUnited States Board of Tax Appeals · 1938
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