Helvering v. Stifel

The Commissioner petitions for a review of the decision of the Board of Tax Appeals in favor of the estate of William F. Stifel, deceased, hereinafter called the taxpayer. The decision of the Board was based upon its earlier decision in the case of Von Gunten v. Commissioner, 28 B. T. A. 702, in which it was held that, where stock of one corporation is exchanged, in pursuance of a plan of reorganization, for stock of another, the cost of the stock thus acquired must be allocated equally to the separate shares acquired, and, when some particular lot of the new shares is sold, the cost thereof…