Legal Opinion

Barber Sec. Corp. v. Commissioner

United States Board of Tax Appeals

Decided October 28, 1941No. Docket No. 100844Published

During 1930 petitioner acquired as a unit an equal number of shares of stock of a bank and a securities corporation. Prior to 1934 the shares were not separately transferable. During that year they were separated. The book values of the shares of both corporations were based on the original cost of the underlying assets, acquired prior to 1930, unadjusted to reflect either depreciation or appreciation.

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During 1930 petitioner acquired as a unit an equal number of shares of stock of a bank and a securities corporation. Prior to 1934 the shares were not separately transferable. During that year they were separated. The book values of the shares of both corporations were based on the original cost of the underlying assets, acquired prior to 1930, unadjusted to reflect either depreciation or appreciation. During the taxable year 1936 the shares of stock of the securities corporation were disposed of and petitioner computed their cost to it by assigning to each stock an amount proportionate to…

1Opinion of the Court

BARBER SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Barber Sec. Corp. v. Commissioner

Docket No. 100844.

United States Board of Tax Appeals

45 B.T.A. 521; 1941 BTA LEXIS 1112;

October 28, 1941, Promulgated

During 1930 petitioner acquired as a unit an equal number of shares of stock of a bank and a securities corporation. Prior to 1934 the shares were not separately transferable. During that year they were separated. The book values of the shares of both corporations were based on the original cost of the underlying assets, acquired prior to 1930, unadjusted…

2Cases cited5 opinions

  1. Hagerman v. CommissionerUnited States Board of Tax Appeals · 1936
  2. Axton v. CommissionerUnited States Board of Tax Appeals · 1935
  3. Green v. CommissionerUnited States Board of Tax Appeals · 1935
  4. Tricou v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Barber Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1941

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