Commissioner v. Libbey

In 1932, the taxpayer owned 121 shares of Androscoggin Corporation 6% Cumulative Preferred A stock, for which she received in that year $12,100. The question is the amount of taxable gain which then occurred. This involves a consideration of the cost basis of the stock. The Board of Tax Appeals took as such basis the market value in 1921, when the stock was turned over to the taxpayer by testamentary trustees who theretofore had held it for her benefit. The Commissioner of Internal Revenue contended and now urges that the cost basis is the market value in 1915 of stock of another corporation,…