McKinney Manufacturing Co. v. Commissioner

OPINION.

OppeR, Judge:

The parties insist, but in unrelated situations, that we can accept as the best evidence of contemporaneous value the sale price agreed upon by buyer and seller when petitioner acquired the property in controversy. We agree as to both items; with the consequence that, contrary to petitioner’s contention as to the good will and to respondent’s contention as to the real estate, we have found as the amount of petitioner’s equity capital invested in these items the agreed figures at which they changed hands at the time. No comparably good evidence of fair market value appears…