Horner v. Commissioner
United States Board of Tax Appeals
Where petitioners, in anticipation of acquisition of new stock through exercise of stock rights, ordered sales of stock and delivered certificates to their broker, who sold shares then owned by them, held sales of old stock were completed transactions, despite petitioners' intention to sell stock not yet acquired, and basis to be used in determining profit is cost of old stock.
1Opinion of the Court
*361OPINION.
Goodrich :
Deficiencies in income tax against Mary E. Horner for tbe year 1927 amounting to $4,190.39; against W. S. Horner for 1928 of $6,193.95; and against Vaughan Horner for 1928 of $1,762.05, are contested in these proceedings which, upon motion, were consolidated. Most of the material facts were stipulated and, although considerable testimony was put in also, we need not, for the purposes of this report, set out a detailed recital of facts. There is no dispute of fact as to the acts done by petitioners; the dispute is as to the effect of those acts, and the whole issue for our…
2Cases cited3 opinions
- Towne v. McElligottDistrict Court, S.D. New York · 1921
- Bingham v. CommissionerUnited States Board of Tax Appeals · 1932
- Turner v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by7 opinions
- Mickler Holding Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- McGinley Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Geoghegan v. CommissionerUnited States Board of Tax Appeals · 1934
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
- Kelchner v. CommissionerUnited States Board of Tax Appeals · 1934
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