FRISCHKORN DEV. CO. v. COMMISSIONER
United States Board of Tax Appeals
1. A promissory note and certain shares of stock held to have had a readily realizable market value. 2. The fair market value of the note and stock determined. 3. In order to avail itself of the benefit of section 203(b)(5) of the Revenue Act of 1924, it is not sufficient for a taxpayer to prove that subsequent to the receipt of money arising from a condemnation award it purchased other property similar and related in use, but it must trace such money into the payments for…
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1. A promissory note and certain shares of stock held to have had a readily realizable market value. 2. The fair market value of the note and stock determined. 3. In order to avail itself of the benefit of section 203(b)(5) of the Revenue Act of 1924, it is not sufficient for a taxpayer to prove that subsequent to the receipt of money arising from a condemnation award it purchased other property similar and related in use, but it must trace such money into the payments for the property purchased, and it is entitled to such benefit only to the extent that it has so traced the money.
1Opinion of the Court
FRISCHKORN DEVELOPMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FRISCHKORN DEV. CO. v. COMMISSIONER
Docket Nos. 30496, 35170, 42452.
United States Board of Tax Appeals
30 B.T.A. 8; 1934 BTA LEXIS 1388;
March 6, 1934, Promulgated
1. A promissory note and certain shares of stock held to have had a readily realizable market value.
2. The fair market value of the note and stock determined.
3. In order to avail itself of the benefit of section 203(b)(5) of the Revenue Act of 1924, it is not sufficient for a taxpayer to prove that subsequent to the receipt of money arising from…
2Cases cited1 opinion
- FRISCHKORN DEV. CO. v. COMMISSIONERUnited States Board of Tax Appeals · 1934