Flynn v. Commissioner
United States Board of Tax Appeals
1. Gain from an exchange of real estate for preferred stock held taxable in the amount of the difference between the basis determined for the real estate to the petitioner and the amount determined to be the fair market value of the preferred stock received in exchange, in the absence of proof of no fair market value or a value less than respondent found. Sales of preferred stock at par value were made to willing buyers on a limited market.
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1. Gain from an exchange of real estate for preferred stock held taxable in the amount of the difference between the basis determined for the real estate to the petitioner and the amount determined to be the fair market value of the preferred stock received in exchange, in the absence of proof of no fair market value or a value less than respondent found. Sales of preferred stock at par value were made to willing buyers on a limited market. Held, sales for par value are evidence that fair market value was the par value. 2. Deduction for loss from the alleged worthlessness of corporate stock…
1Opinion of the Court
JOHN J. FLYNN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Flynn v. Commissioner
Docket No. 76599.
United States Board of Tax Appeals
35 B.T.A. 1064; 1937 BTA LEXIS 802;
April 30, 1937, Promulgated
1. Gain from an exchange of real estate for preferred stock held taxable in the amount of the difference between the basis determined for the real estate to the petitioner and the amount determined to be the fair market value of the preferred stock received in exchange, in the absence of proof of no fair market value or a value less than respondent found. Sales of preferred stock at par…
2Cases cited1 opinion
- Flynn v. CommissionerUnited States Board of Tax Appeals · 1937