Dodge v. Commissioner
United States Board of Tax Appeals
1. A valuation of stock as of March 1, 1913, made by the Commissioner's predecessor in office at the request of a taxpayer before any sale had been consummated, does not preclude the Commissioner from placing a different valuation on the stock as of that date in determining tax liability resulting from the sale thereof.
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1. A valuation of stock as of March 1, 1913, made by the Commissioner's predecessor in office at the request of a taxpayer before any sale had been consummated, does not preclude the Commissioner from placing a different valuation on the stock as of that date in determining tax liability resulting from the sale thereof. James Couzens,11 B.T.A. 1040; Rosetta V. Hauss,12 B.T.A. 755. 2. Upon the authority of the cases cited above, held that shares of stock of the Ford Motor Co. sold by the taxpayer had a fair market value on March 1, 1913, of $10,000 per share. 3. A waiver of the time prescribed…
1Opinion of the Court
*214OPINION.
MaRQUette:
This proceeding is one of nine proceedings consolidated for hearing because a large volume of the evidence was relevant and material to all of them, and having in common two issues, as follows: (1) Whether, under the circumstances shown by the evidence, the question of the fair market price or value on March 1, 1913, of the stock of the Ford Motor Co. and the basis for computing the gain on its sale in 1919, was open to the respondent in determining a deficiency or rejecting a claim in abatement antecedent to this proceeding, and is open for redetermination in this…
2Cases cited13 opinions
- Allen v. DuffieMichigan Supreme Court · 1880
- McHugh v. Estate of DowdMichigan Supreme Court · 1891
- Durfee v. AbbottMichigan Supreme Court · 1883
- Underwood v. WaldronMichigan Supreme Court · 1863
- Comstock v. HowdMichigan Supreme Court · 1867
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Anderson v. United StatesUnited States Court of Claims · 1936
- Dodge v. CommissionerUnited States Board of Tax Appeals · 1928