Barber Sec. Corp. v. Commissioner
United States Board of Tax Appeals
During 1930 petitioner acquired as a unit an equal number of shares of stock of a bank and a securities corporation. Prior to 1934 the shares were not separately transferable. During that year they were separated. The book values of the shares of both corporations were based on the original cost of the underlying assets, acquired prior to 1930, unadjusted to reflect either depreciation or appreciation.
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During 1930 petitioner acquired as a unit an equal number of shares of stock of a bank and a securities corporation. Prior to 1934 the shares were not separately transferable. During that year they were separated. The book values of the shares of both corporations were based on the original cost of the underlying assets, acquired prior to 1930, unadjusted to reflect either depreciation or appreciation. During the taxable year 1936 the shares of stock of the securities corporation were disposed of and petitioner computed their cost to it by assigning to each stock an amount proportionate to…
1Opinion of the Court
*526OPINION.
Van Fossan:
The questions raised for decision are two: Whether it is practicable to apportion a part of the cost to petitioner of the units of the Chase Bank and Amerex stock to the Amerex stock sold by petitioner during the taxable year; and similarly, whether it is practicable to apportion a part of the cost to petitioner of the units of Commercial Bank and Commercial Corporation stock to the Commercial Corporation stock which was liquidated during the taxable year. The problems with respect to the practicability of apportionment are identical in the case of both pairs of…
2Cited by1 opinion
- Barber Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1941