Rogers v. Commissioner
United States Board of Tax Appeals
1. Stock acquired through the exercise of stock rights does not constitute a capital asset, either wholly or in part, unless held for a period of more than two years commencing from the date of acquisition of such stock.
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1. Stock acquired through the exercise of stock rights does not constitute a capital asset, either wholly or in part, unless held for a period of more than two years commencing from the date of acquisition of such stock. Rodman E. Griscom,22 B.T.A. 979, and Ellen Ayer Wood,29 B.T.A. 1050, followed. 2. Dividing the sum of the basis of the stock with respect to which the stock rights were issued and the subscription price of the new stock by the total number of old and new shares, held, to be a reasonable method of determining the basis for each share of the new stock under the prevailing facts.
1Opinion of the Court
MAY ROGERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
HORACE S. TUTHILL, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
EDNA MAY THRALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rogers v. Commissioner
Docket Nos. 45051, 52448, 52449, 55546.
United States Board of Tax Appeals
32 B.T.A. 1176; 1935 BTA LEXIS 842;
August 8, 1935, Promulgated
1. Stock acquired through the exercise of stock rights does not constitute a capital asset, either wholly or in part, unless held for a period of more than two years commencing from the date of acquisition of…
2Cases cited10 opinions
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Rogers v. CommissionerUnited States Board of Tax Appeals · 1935
- Safe Deposit & Trust Co. of Baltimore v. MilesDistrict Court, D. Maryland · 1921
- Griscom v. CommissionerUnited States Board of Tax Appeals · 1931
- Insull v. CommissionerUnited States Board of Tax Appeals · 1935
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