Legal Opinion

St. Louis Union Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided April 13, 1934No. Docket No. 65675PublishedCited by 5 opinions

1. In the absence of evidence showing that the fair market value of securities received by the petitioners from the executors of the estate of John I. Beggs was other than the prices at which the securities sold on the New York Stock Exchange on the dates the petitioners received them, it is held that the quoted prices for them on the dates of receipt represent their fair market values. 2. In 1929 the petitioners received certain stock rights, which were not exercised by the…

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1. In the absence of evidence showing that the fair market value of securities received by the petitioners from the executors of the estate of John I. Beggs was other than the prices at which the securities sold on the New York Stock Exchange on the dates the petitioners received them, it is held that the quoted prices for them on the dates of receipt represent their fair market values. 2. In 1929 the petitioners received certain stock rights, which were not exercised by the petitioners and which became worthless in their hands in 1929. Held, that the petitioners sustained no deductible loss…

1Opinion of the Court

*376OPINION.

Smith:

The first question presented by this proceeding is the cost basis to be used in determining the amount of profit realized by the petitioners from the sale in 1929 of 60,263 shares of North American Co. common stock for $6,561,914.62. The petitioners contend that the correct basis is the fair market value of the shares at the time received by them as trustees and that such fair market value is the sum of the products obtained by multiplying the number of shares received from the executors on certain dates by the closing quoted selling price of the shares on the New York Stock…

2Cases cited7 opinions

  1. R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
  2. Anderson v. WilsonSupreme Court of the United States · 1933
  3. Johnson v. United States Shipping Bd. Emergency Fleet CorporationSupreme Court of the United States · 1930
  4. Kenaday v. SinnottSupreme Court of the United States · 1901
  5. Kier v. CommissionerUnited States Board of Tax Appeals · 1933

2 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. G. E. Employees Securities Corp. v. ManningDistrict Court, D. New Jersey · 1941
  2. Brumder v. United StatesDistrict Court, E.D. Wisconsin · 1944
  3. Eastern Shares Corp. v. CommissionerUnited States Board of Tax Appeals · 1935
  4. Palmer v. CommissionerUnited States Board of Tax Appeals · 1935
  5. St. Louis Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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