Legal Opinion

Gibson v. Commissioner

United States Board of Tax Appeals

Decided July 9, 1941No. Docket No. 100433Published

The receipt of warrants, representing rights to subscribe to preferred stock of a corporation by the petitioner, who was a holder of its common stock, and having a fair market value at the time of such receipt, constituted taxable income under the provisions of section 22(a) and (d) and section 115(f)(1) of the Revenue Act of 1936.

1Opinion of the Court

HELEN WHITNEY GIBSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Gibson v. Commissioner

Docket No. 100433.

United States Board of Tax Appeals

44 B.T.A. 950; 1941 BTA LEXIS 1253;

July 9, 1941, Promulgated

The receipt of warrants, representing rights to subscribe to preferred stock of a corporation by the petitioner, who was a holder of its common stock, and having a fair market value at the time of such receipt, constituted taxable income under the provisions of section 22(a) and (d) and section 115(f)(1) of the Revenue Act of 1936.

Frederick E. Winkler, Esq., for the petitioner.

Geor…

2Cases cited11 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. United States v. PhellisSupreme Court of the United States · 1921
  3. Koshland v. HelveringSupreme Court of the United States · 1936
  4. Palmer v. CommissionerSupreme Court of the United States · 1937
  5. Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922

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