Neville v. Commissioner
United States Board of Tax Appeals
When shares of stock in a corporation or an association are sold from lots purchased at different dates and at different prices and the identity of the shares sold can be determined from the certificates delivered, gain or loss must be computed upon the cost or other basis of the shares represented by the certificates delivered.
1Opinion of the Court
OPINION.
Smith :
The petitioner, seeks the redetermination of a deficiency in income tax for 1929 in the amount of $356.98.
The petitioner is engaged in business on his own account as a dealer and broker in securities in Boston, Massachusetts. He is also the treasurer of the Standard Securities Co., an association with transferable shares whose headquarters and transfer offices are in the office of the petitioner.
On December 28, 1929, the petitioner sold to the Standard Securities Co. 500 shares of Standard Securities Co. stock for the sum of $9,750. The following certificates, acquired on the…
2Cases cited5 opinions
- DeGanay v. LedererSupreme Court of the United States · 1919
- Towne v. McElligottDistrict Court, S.D. New York · 1921
- Stewart v. CommissionerUnited States Board of Tax Appeals · 1929
- Turner v. CommissionerUnited States Board of Tax Appeals · 1932
- Heinz v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by3 opinions
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
- Kelchner v. CommissionerUnited States Board of Tax Appeals · 1934
- Neville v. CommissionerUnited States Board of Tax Appeals · 1933