Legal Opinion

Hoffer v. Commissioner

United States Board of Tax Appeals

Decided September 16, 1931No. Docket Nos. 33374, 33375Published

1. The basic date for valuing stock received as part consideration upon the sale of property is the date when taxpayer is entitled to receive the stock and not the date the stock certificates were delivered to the vendor. 2. The fair market value of shares of stock determined.

1Opinion of the Court

ANITA OWENS HOFFER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

T. B. HOFFER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hoffer v. Commissioner

Docket Nos. 33374, 33375.

United States Board of Tax Appeals

24 B.T.A. 22; 1931 BTA LEXIS 1708;

September 16, 1931, Promulgated

1. The basic date for valuing stock received as part consideration upon the sale of property is the date when taxpayer is entitled to receive the stock and not the date the stock certificates were delivered to the vendor.

2. The fair market value of shares of stock determined.

J. S. Y. Ivins, Esq.,…

2Cases cited17 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Boom Co. v. PattersonSupreme Court of the United States · 1879
  3. United States v. Chandler-Dunbar Water Power Co.Supreme Court of the United States · 1913
  4. Richardson v. ShawSupreme Court of the United States · 1908
  5. Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930

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