City Builders Finance Co. v. Commissioner

*803OPINION.

Love:

The facts in this case are not controverted. Of course, in solving this problem, we must solve it in the light of, and in harmony with, the income tax laws.. The applicable statute is section 204 (a) of the Revenue Act of 1924, which is as follows:

The basis for determining the gain or loss from the sale or other disposition of property acquired after February 28, 1913, shall be the cost of such property.

Petitioner, in May, 1923, purchased 32½ shares out of a total issue of 260 shares of the Palm Beach Estates, Inc., stock, at a cost of $25,000, that is, at a cost per share (not…