Legal Opinion

Martin v. W. Hall v. Commissioner

United States Tax Court

Decided June 21, 1945No. Docket No. 4246Unpublished

Petitioner acquired on different dates as a unit an equal number of shares of a bank and a securities corporation. He sold during the taxable year shares of the bank and here seeks an allocation of cost for purposes of determining amount of loss sustained. Held, evidence does not furnish a factual basis upon which to make an apportionment. Barber Securities Corp., 45 B.T.A. 521, followed.

1Opinion of the Court

Martin V. W. Hall v. Commissioner.

Martin v. W. Hall v. Commissioner

Docket No. 4246.

United States Tax Court

1945 Tax Ct. Memo LEXIS 154; 4 T.C.M. (CCH) 642; T.C.M. (RIA) 45208;

June 21, 1945

Petitioner acquired on different dates as a unit an equal number of shares of a bank and a securities corporation. He sold during the taxable year shares of the bank and here seeks an allocation of cost for purposes of determining amount of loss sustained. Held, evidence does not furnish a factual basis upon which to make an apportionment. Barber Securities Corp., 45 B.T.A. 521, followed.

Charles A. Roberts,…

2Cases cited5 opinions

  1. Hagerman v. CommissionerUnited States Board of Tax Appeals · 1936
  2. Orvilletta, Inc. v. CommissionerUnited States Board of Tax Appeals · 1942
  3. Barber Securities Corp. v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Green v. CommissionerUnited States Board of Tax Appeals · 1935
  5. deCoppet v. CommissionerUnited States Board of Tax Appeals · 1938

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