Kelly v. Commissioner
United States Board of Tax Appeals
Where preferred stock was received as a dividend on common stock, which was the only class of stock theretofore authorized and outstanding, held, that the basis of the dividend stock on subsequent disposition is zero rather than some allocated portion of the basis of the common stock on which it was declared.
1Opinion of the Court
FRANK J. AND HUBERT KELLY TRUST, NORTHWESTERN NATIONAL BANK AND TRUST COMPANY OF MINNEAPOLIS, AND MRS. IRENE KELLY COLLISSON, AS TRUSTEES OF SAID TRUST, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Kelly v. Commissioner
Docket No. 92946.
United States Board of Tax Appeals
38 B.T.A. 1014; 1938 BTA LEXIS 801;
October 25, 1938, Promulgated
Where preferred stock was received as a dividend on common stock, which was the only class of stock theretofore authorized and outstanding, held, that the basis of the dividend stock on subsequent disposition is zero rather than some allocated…
2Cases cited13 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Helvering v. GowranSupreme Court of the United States · 1937
- Koshland v. HelveringSupreme Court of the United States · 1936
- Lynch v. HornbySupreme Court of the United States · 1918
- Peabody v. EisnerSupreme Court of the United States · 1918
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