Williamson v. Commissioner
United States Board of Tax Appeals
Petitioner acquired certain stocks from the estate of her husband who died intestate. The stocks decreased in value between the time of the death of the decedent and the time of their distribution to petitioner. In 1932 and 1933 she sold part of the stocks thus acquired for amounts in excess of the value of the stocks at the time of their distribution to her but not in excess of the value of these stocks at the time of the decedent's death.
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Petitioner acquired certain stocks from the estate of her husband who died intestate. The stocks decreased in value between the time of the death of the decedent and the time of their distribution to petitioner. In 1932 and 1933 she sold part of the stocks thus acquired for amounts in excess of the value of the stocks at the time of their distribution to her but not in excess of the value of these stocks at the time of the decedent's death. Held: (1) Petitioner's basis for gain or loss is the fair market value of the stocks sold at the time of their distribution to her, as provided in section…
1Opinion of the Court
*669OPINION.
Mellott:
Petitioner seeks a redetermination of the deficiency in income taxes determined by the respondent for the calendar years 1932 and 1933, in the amount of $20,080.22, of which $12,323.69 is for the calendar year 1932, and the balance, or $7,756.53, for the calendar year 1933. All of the facts have been stipulated. The deficiency results from respondent’s determination that petitioner realized taxable gain when she sold certain shares of stock acquired from the estate of her husband. The principal question in dispute is the basis to be used in computing the gain or loss upon the…
2Cases cited4 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- McFeely v. CommissionerSupreme Court of the United States · 1935
- Taft v. BowersSupreme Court of the United States · 1929
- Goodrich v. EdwardsSupreme Court of the United States · 1921
3Cited by3 opinions
- Williamson v. CommissionerCourt of Appeals for the Sixth Circuit · 1938
- Campbell v. CommissionerUnited States Board of Tax Appeals · 1939
- Williamson v. CommissionerUnited States Board of Tax Appeals · 1936