Thomas v. Commissioner
United States Board of Tax Appeals
In an exchange of a definite part of petitioners' holdings of stock in a bank, going out of business, for a definite amount of stock in another bank which then had a market value, and for "certificates of shares" in a liquidating company, which certificates later in the taxable year proved to be worthless and were sold for $1, petitioners suffered a deductible loss to the extent of the cost of their original stock, less the value of stock received plus the $1 received for…
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In an exchange of a definite part of petitioners' holdings of stock in a bank, going out of business, for a definite amount of stock in another bank which then had a market value, and for "certificates of shares" in a liquidating company, which certificates later in the taxable year proved to be worthless and were sold for $1, petitioners suffered a deductible loss to the extent of the cost of their original stock, less the value of stock received plus the $1 received for those certificates.
1Opinion of the Court
*1344OPINION.
Love:
The respondent, through his attorney, contends that under the facts above set forth, the petitioners have sustained no deductible loss under the Revenue Act of 1921, and cites the provisions of section 202 thereof, as follows:(c) For the purposes of this title, on an exchange of property, real, personal or mixed, for any other such property, no gain or loss shall be recognized unless the property received in exchange has a readily realizable market value; but even if the property received in exchange has a readily realizable market value, no gain or loss shall be recognized.
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2Cited by3 opinions
- C. H. Mead Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Central Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1934
- Thomas v. CommissionerUnited States Board of Tax Appeals · 1929