Biscayne Bay Islands Co. v. Commissioner (A)
United States Board of Tax Appeals
1. The cost to a corporation of a tract of land acquired for its entire stock, for computing gain or loss from subsequent sales of lots carved therefrom, is to be determined upon the basis of the fair market value of the land when acquired; and the finding of such fair market value is made upon the entire evidence, consisting of earlier transactions in other property, later sales of the stock and of some of the lots, opinions of witnesses, and detailed circumstances of the…
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1. The cost to a corporation of a tract of land acquired for its entire stock, for computing gain or loss from subsequent sales of lots carved therefrom, is to be determined upon the basis of the fair market value of the land when acquired; and the finding of such fair market value is made upon the entire evidence, consisting of earlier transactions in other property, later sales of the stock and of some of the lots, opinions of witnesses, and detailed circumstances of the acquisition and the plans and expectations of the promoters of the venture. 2. Where a tract of land is purchased and…
1Opinion of the Court
*734OPINION.
SteRNi-iagen :
The proceeding involves several questions which arise in the course of determining the petitioner’s gain in the sale of its lots on Palm and Hibiscus Islands at Miami, Fla. As to 1922, the Commissioner determined an overassessment, and this is not before us. Cornelius Cotton Mills, 4 B. T. A. 255.
íSi'TJhe petitioner contends that when it acquired the land in March, 1918,* in exchange for its shares, the land was worth $300,000, the par value of its shares; while the respondent contends that the land was worth no more than $40,173.33, which it had cost the syndicate…
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