Credit & Inv. Corp. v. Commissioner
United States Board of Tax Appeals
In 1926, petitioner, an American corporation, purchased a bond of a German corporation, payable in dollars. In 1933 a German law was enacted providing that such obligations should be paid in marks, the use and transfer of which were subject to restrictions. Permission of the German Government was required for the transfer of the to use them in the purchase of securities listed on German stock exchanges.
Read the full summary
In 1926, petitioner, an American corporation, purchased a bond of a German corporation, payable in dollars. In 1933 a German law was enacted providing that such obligations should be paid in marks, the use and transfer of which were subject to restrictions. Permission of the German Government was required for the transfer of the to use them in the purchase of securities listed on German stock exchanges. In 1935 the German corporation paid petitioner in petitioner invested a portion of them in securities of other German corporations. During the taxable year it sold these securities, receiving…
1Opinion of the Court
*677OPINION.
Mellott:
Petitioner contends that its basis for the computation of gain or loss upon the sale, in the taxable year,1 of the German securities purchased by it in 19351 upon the Bourse, was $145,408.98. This'amount is the allocable portion of the sum originally invested by it in the Ostdeutsch bond. Respondent determined that the basis is the cost of the securities purchased in 1935 ($51,842.92), which is equivalent to the quoted price of “blocked” marks ($0.1437) on the New York market at the time the purchase was made and which he determined was the fair market value of the 360,771.89…
2Cases cited2 opinions
- Perry v. United StatesSupreme Court of the United States · 1935
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
3Cited by13 opinions
- Durovic v. CommissionerUnited States Tax Court · 1970
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Ferdinand Cinelli and Sarah M. Cinelli v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1974
- American Natural Gas Co. v. United StatesUnited States Court of Claims · 1960
- American Natural Gas Co. v. United StatesUnited States Court of Claims · 1960
8 more not listed; retrieve them via the Exa API.