Myers v. Commissioner

*47OPINION.

Adams :

Under the facts as found, the sole question presented for determination is:

Was the $200,000, a part of the consideration for the stock in question, income to the petitioner for the year 1928 ?

The respondent contends that title to the securities passed from the petitioner to the purchaser; that delivery was made and the agreed consideration was paid in full; that the transaction was closed as between the seller and purchaser, and the entire- amount of the consideration must be considered in determining the profit or loss arising from the sale.

Petitioner argues in his brief that…