Piper v. Commissioner
United States Tax Court
Common stock subscription warrants were acquired by petitioner along with shares of common stock, as a unit. Held, the warrants had value when received by petitioner; held, further, under the circumstances there is no practical basis upon which an allocation of cost as between the warrants and the stock can be made.
1Opinion of the Court
OPINION.
ARundell, Judge:
The petitioner exchanged his investment in the old company for shares of common stock and common stock subscription warrants in the new company. The exchange was one in which no gain or loss was recognized. No allocation of value was made between the stock and the subscription warrants at the time they were issued to petitioner. Petitioner subsequently sold the warrants in 1940, at 50 cents each, or for a total consideration of $28,500. The respondent takes the view that the warrants had neither fair market value nor actual value at the date of issuance, November…
2Cases cited2 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
3Cited by23 opinions
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
- United Mercantile Agencies, Inc. v. CommissionerUnited States Tax Court · 1955
- Cleveland-Sandusky Brewing Corp. v. CommissionerUnited States Tax Court · 1958
- William T. Gladden Nicole L. Gladden v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- Drybrough v. CommissionerUnited States Tax Court · 1964
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