Legal Opinion

Fuller v. Commissioner

United States Board of Tax Appeals

Decided September 14, 1934No. Docket No. 73759Published

BASIS OF COST OF STOCK RECEIVED IN NONTAXABLE EXCHANGE SPLITUP. - On September 3, 1929, petitioner was the holder of 54,054 shares of stock, $10 par value, in the Packard Motor Car Co. On that date he received in exchange for these shares 270,270 shares of stock, no par value, in the same company, representing a splitup of 5 for 1. In the taxable year 1930 the petitioner sold 25,000 shares of the 270,270 shares thus received.

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BASIS OF COST OF STOCK RECEIVED IN NONTAXABLE EXCHANGE SPLITUP. - On September 3, 1929, petitioner was the holder of 54,054 shares of stock, $10 par value, in the Packard Motor Car Co. On that date he received in exchange for these shares 270,270 shares of stock, no par value, in the same company, representing a splitup of 5 for 1. In the taxable year 1930 the petitioner sold 25,000 shares of the 270,270 shares thus received. Held, the basis for computing the gain on the sale is the average cost of each of the 270,270 shares received in exchange, according to the rule laid down in Christian…

1Opinion of the Court

ALVAN T. FULLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Fuller v. Commissioner

Docket No. 73759.

United States Board of Tax Appeals

31 B.T.A. 154; 1934 BTA LEXIS 1145;

September 14, 1934, Promulgated

BASIS OF COST OF STOCK RECEIVED IN NONTAXABLE EXCHANGE SPLITUP. - On September 3, 1929, petitioner was the holder of 54,054 shares of stock, $10 par value, in the Packard Motor Car Co. On that date he received in exchange for these shares 270,270 shares of stock, no par value, in the same company, representing a splitup of 5 for 1. In the taxable year 1930 the petitioner sold…

2Cases cited4 opinions

  1. Von Gunten v. CommissionerUnited States Board of Tax Appeals · 1933
  2. Mickler Holding Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Oliver v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Fuller v. CommissionerUnited States Board of Tax Appeals · 1934

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