Markle v. Commissioner
United States Board of Tax Appeals
1. GAIN OR LOSS. - Petitioners in 1920 disposed of all their stocks and bonds in two corporations and all their bonds in a third company for cash and bonds of a new corporation organized by the purchasers.
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1. GAIN OR LOSS. - Petitioners in 1920 disposed of all their stocks and bonds in two corporations and all their bonds in a third company for cash and bonds of a new corporation organized by the purchasers. The amount of gain resulting thereby is redetermined under paragraph (b) of section 202 of the Revenue Act of 1918. 2. GAIN OR LOSS. - Some of the petitioners inherited their securities prior and some subsequent to March 1, 1913, and some of the securities were owned by estates at the time disposed of in 1920. Held, that where such securities were acquired prior to March 1, 1913, the basis…
1Opinion of the Court
*785OPINION.
GreeN:
The broad question presented in these proceedings is the amount of the gain resulting from the disposition by the several petitioners during 1920 of all their stocks and bonds in the old companies for cash and bonds in the new company. This question may be conveniently divided into three subquestions: (1) What is the basis for determining gain or loss under section 202 of the Revenue Act of 1918 in those cases where the property disposed of in 1920 *786had been inherited by the person making the disposition or was owned by an estate? (2) Did the transaction by virtue of which the…
2Cases cited6 opinions
- United States v. FlannerySupreme Court of the United States · 1925
- McCaughn v. LudingtonSupreme Court of the United States · 1925
- Goodrich v. EdwardsSupreme Court of the United States · 1921
- Walsh v. BrewsterSupreme Court of the United States · 1921
- In Re Estate of FeltonCalifornia Supreme Court · 1917
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Markle v. CommissionerUnited States Board of Tax Appeals · 1928