Geoghegan v. Commissioner
United States Board of Tax Appeals
When a taxpayer sells a portion of his shares in a corporation, the delivery of the earlier acquired certificates is evidence of his intention to sell the earlier acquired shares.
1Opinion of the Court
*94OPINION.
SteRniiagen:
The respondent’s determination treats the shares sold by petitioner in 1927 as being some of those acquired in 1925 and measures the gain as the difference between the cost of such shares and the total sale price. Petitioner contends that the basis to be used as to 1,800 shares is the cost of those shares which he bought in 1927. The foundation upon which petitioner rests is his present testimony that he intended to sell the later acquired shares.
We think, however, that the evidence shows otherwise. It shows that, if any identification as to shares could have been…
2Cases cited7 opinions
- Hedrick v. CommissionerUnited States Board of Tax Appeals · 1931
- Stryker v. CommissionerUnited States Board of Tax Appeals · 1930
- Horner v. CommissionerUnited States Board of Tax Appeals · 1933
- Turner v. CommissionerUnited States Board of Tax Appeals · 1932
- Snyder v. CommissionerUnited States Board of Tax Appeals · 1933
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
- Allington v. CommissionerUnited States Board of Tax Appeals · 1934
- Geoghegan v. CommissionerUnited States Board of Tax Appeals · 1934