Clark v. Commissioner
United States Board of Tax Appeals
1. STOCK DIVIDEND - SEC. 201(f), REVENUE ACT OF 1926. - A distribution among shareholders in exchange for old common stock, of preferred stock and an increased amount of common stock, in the same proportion, so far as the record discloses, in which the old common stock was held, is a stock dividend, therefore non-taxable, and does not change the basis for determining gain upon later disposition of the stock received in such exchange.
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1. STOCK DIVIDEND - SEC. 201(f), REVENUE ACT OF 1926. - A distribution among shareholders in exchange for old common stock, of preferred stock and an increased amount of common stock, in the same proportion, so far as the record discloses, in which the old common stock was held, is a stock dividend, therefore non-taxable, and does not change the basis for determining gain upon later disposition of the stock received in such exchange. Pearl B. Brown, Executrix,26 B.T.A. 901, followed. 2. EXCHANGE OF STOCK FOR STOCK - SEC. 203(b)(2), REVENUE ACT OF 1926. - Upon the facts held, an exchange of…
1Opinion of the Court
FRANCES ELLIOTT CLARK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Clark v. Commissioner
Docket No. 54735.
United States Board of Tax Appeals
28 B.T.A. 1225; 1933 BTA LEXIS 1039;
August 22, 1933, Promulgated
1. STOCK DIVIDEND - SEC. 201(f), REVENUE ACT OF 1926. - A distribution among shareholders in exchange for old common stock, of preferred stock and an increased amount of common stock, in the same proportion, so far as the record discloses, in which the old common stock was held, is a stock dividend, therefore non-taxable, and does not change the basis for determining gain upon…
2Cases cited2 opinions
- Brown v. CommissionerUnited States Board of Tax Appeals · 1932
- Clark v. CommissionerUnited States Board of Tax Appeals · 1933