Tirrell v. Commissioner
United States Board of Tax Appeals
Held, under the facts presented, the petitioner's sale of stock was not an involuntary conversion thereof within the meaning of section 214(a) 12 of the Revenue Act of 1921.
1Opinion of the Court
*1401OPINION.
Teammell :
It is the contention of the petitioner that the sale of the stock in the Reynolds <& Tirrell Co. to Reynolds and the subsequent reinvestment of the $200,000 received therefrom in the Tirrell Brothers Silk Co. amounted to an involuntary conversion of assets under section 214 (a) (12) of the Revenue Act of 1921, and that the capital gain of $193,400 realized from said sale to Reynolds is therefore nontaxable.
There is no controversy over the fact that the petitioner acquired this stock for $6,600 in October, 1913, and sold it in 1923 for $200,000, the only controversy being as…
2Cited by8 opinions
- Dear Publication & Radio, Inc. v. CommissionerUnited States Tax Court · 1959
- Dorothy C. Thorpe Glass Mfg. Corp. v. CommissionerUnited States Tax Court · 1968
- Hitke v. CommissionerCourt of Appeals for the Seventh Circuit · 1961
- Robert K. Hitke and La Verne E. Hitke v. Commissioner of Internal Revenue, Robert L. Dahme and Dolores K. Dahme v. Commissioner of Internal Revenue, Kurt Hitke and Anna Hitke v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Carver v. CommissionerUnited States Tax Court · 1985
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