Seas Shipping Co. v. Commissioner
United States Tax Court
1. Petitioner sold 10 ships to Moore-McCormack Lines, Inc., for cash, notes and 300,000 shares of Moore-McCormack stock. Said 300,000 shares constituted 13 percent of Moore-McCormack's outstanding stock thereafter. Held: For purposes of determining petitioner's gain on the sale of its ships, the 300,000 shares received had a value of $30 per share. Moore-McCormack Lines, Inc., 44 T.C.
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1. Petitioner sold 10 ships to Moore-McCormack Lines, Inc., for cash, notes and 300,000 shares of Moore-McCormack stock. Said 300,000 shares constituted 13 percent of Moore-McCormack's outstanding stock thereafter. Held: For purposes of determining petitioner's gain on the sale of its ships, the 300,000 shares received had a value of $30 per share. Moore-McCormack Lines, Inc., 44 T.C. (August 27, 1965), a companion case involving the same question of fact, followed. 2. Held: Petitioner is entitled to a deduction for depreciation, including depreciation on all capitalized improvements, on the…
1Opinion of the Court
Seas Shipping Company, Inc. v. Commissioner.
Seas Shipping Co. v. Commissioner
Docket No. 3105-62.
United States Tax Court
T.C. Memo 1965-240; 1965 Tax Ct. Memo LEXIS 92; 24 T.C.M. (CCH) 1222; T.C.M. (RIA) 65240;
August 31, 1965
1. Petitioner sold 10 ships to Moore-McCormack Lines, Inc., for cash, notes and 300,000 shares of Moore-McCormack stock. Said 300,000 shares constituted 13 percent of Moore-McCormack's outstanding stock thereafter. Held: For purposes of determining petitioner's gain on the sale of its ships, the 300,000 shares received had a value of $30 per share. Moore-McCormack Lines,…
2Cases cited36 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Danielson v. CommissionerUnited States Tax Court · 1965
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Illinois Merchants Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Elmhurst Cemetery Co. of Joliet v. CommissionerSupreme Court of the United States · 1937
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