Robins v. Commissioner
United States Board of Tax Appeals
1. Held, under facts presented, petitioner's sale of stock was not an involuntary conversion thereof within the meaning of section 214(a)(12) of the Revenue Act of 1921. 2. Held, under the facts presented, that the petitioner's sale of stock was not a transaction amounting to a reorganization such as to give rise to any gain or loss.
1Opinion of the Court
*1071OPINION.
Milliken :
The respondent determined that the petitioner realized a taxable gain of $30,966 by reason of the sale of his stock in the Thompson-Munro-Eobins Chemical Co. to Thompson in the year 1923. There is no dispute between the parties concerning the computation of gain determined by the respondent if the sale by petitioner is not governed by section 214 (a) (12) of the Eevenue Act of 1921 or was not a mere reorganization giving rise to no gain or loss.
Congress in the Eevenue Act of 1921 added subdivision 214 (a) (12) which provides as follows:
Sec. 214. (a) That in computing net…
2Cited by9 opinions
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- Robert K. Hitke and La Verne E. Hitke v. Commissioner of Internal Revenue, Robert L. Dahme and Dolores K. Dahme v. Commissioner of Internal Revenue, Kurt Hitke and Anna Hitke v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
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