Pickard v. Commissioner

The taxpayer contracted to sell 300 shares of Station stock for $175,200, a price greatly in excess of its cost. For the admitted purpose of avoiding a tax on tjie profit he would realize if paid in cash, he engaged in an elaborate series of transactions which resulted in giving him $3,700 in cash and the stock of two newly created corporations whose assets consisted of United States Treasury notes equal in value to the balance of the purchase price of the Station stock. He contends that he is relieved from tax because each of the steps in his elaborate plan is a non-taxable transaction…