Marr v. United States

Prior to March 1, 1913, Marr and wife purchased 339 shares of the preferred and 425 shares of the common stock of the General Motors Company-of New Jersey for $76,400. In 1916, they received in exchange for this stock 451 shares, of-the preferred- and 2,125 shares of- the common stock of the General Motors Corporation of Delaware which (including a small cash payment) had the aggregate market value of $400,866.57.’ The difference between the cost of their stock in the New Jersey corporation and the value of the stock in the Delaware corporation was $324,466.57. The Treasury Department ruled…