Downing v. Commissioner
United States Board of Tax Appeals
1. Respondent's determination of March 1, 1913, value of certain shares of stock sold sustained for lack of evidence proving error. 2. In 1920 the petitioners sold the stock and received in that year payments in excess of 33 per cent of the sales price. Held, the petitioners are not entitled to report the profit realized on the transaction on an installment basis.
1Opinion of the Court
*1183OPINION.
Arundell:
In computing the profit realized by the estate on the sale of 1,190 shares of stock of J. It. Downing Co. to the Porter-Milton Ice Co., the respondent used a March 1, 1913, value for the stock of $131,102.37. The petitioners assert that there were no sales of the shares at or about March 1, 1913, and that their value can be determined only by a resort to the assets of the corporation, which assets they claim were on March 1,1913, worth $171,181.50, including good will of a value of $40,000.
From the testimony of petitioners’ two witnesses, Jere It. Downing, president of J. R.…
2Cited by3 opinions
- Downing v. CommissionerUnited States Board of Tax Appeals · 1928
- Graham v. CommissionerUnited States Tax Court · 1976
- Kennedy v. CommissionerUnited States Board of Tax Appeals · 1929