Forrester v. Commissioner
United States Board of Tax Appeals
From April to June 1929 petitioner purchased through his broker, on margin, 1,600 shares of common stock of the P Corporation, certificates for which were delivered to him on July 8 and July 20. On July 16 he purchased through the same broker, also on margin, 3,000 shares of the same stock.
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From April to June 1929 petitioner purchased through his broker, on margin, 1,600 shares of common stock of the P Corporation, certificates for which were delivered to him on July 8 and July 20. On July 16 he purchased through the same broker, also on margin, 3,000 shares of the same stock. Thereafter, on various dates from October 26 through December 27, petitioner delivered to his broker, to be placed in his margin account, 1,100 of the 1,600 shares purchased by him earlier in 1929, 900 shares purchased before June 1927, and 300 shares purchased after July 17, 1929. On various dates between…
1Opinion of the Court
OPINION.
Matthews:
This proceeding involves a deficiency in petitioner’s income tax for the calendar year 1929 in the amount of $2,546.46. At the hearing the respondent moved for an increase in the deficiency on the ground that the revenue agent had erred in the calculation of the deficiency determined. A single issue is involved, whether the “ first in, first out ” rule, admittedly applicable to the sale of shares held in a broker’s margin account, was correctly applied by the respondent, where petitioner’s earliest purchased shares were put into his broker’s account after various other later…
2Cited by2 opinions
- Morrill v. United StatesDistrict Court, D. New Hampshire · 1937
- Forrester v. CommissionerUnited States Board of Tax Appeals · 1935