Musser v. Commissioner
United States Board of Tax Appeals
The taxpayer owned certain shares of stock in a national bank, which, in 1919, was consolidated under a modification of its own charter with two other national banks and its name changed. Upon consolidation the taxpayer received 1 1/3 shares of stock in the consolidated bank for each share of stock owned previously.
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The taxpayer owned certain shares of stock in a national bank, which, in 1919, was consolidated under a modification of its own charter with two other national banks and its name changed. Upon consolidation the taxpayer received 1 1/3 shares of stock in the consolidated bank for each share of stock owned previously. Held, that the taxpayer exchanged certificates of stock in one national bank for a larger number of shares of stock in a consolidated national bank and that the taxpayer is liable to income tax in respect of the difference between the market value of the shares of stock received…
1Opinion of the Court
*1036OPINION.
Smith:
In his petition the taxpayer alleges that the Commissioner erred in his finding that the taxpayer realized a profit of $4,506 in the year 1919 from an alleged exchange of shares of stock in the Third National Bank of St. Louis for shares of stock in First National Bank in St. Louis. The method of determining the profit is set forth in the findings of fact. No evidence has been presented before this Board that the cost to the taxpayer or the March 1, 1913, value of the shares of stock of the Third National Bank of St. Louis was different from the amount found by the Commissioner…
2Cases cited9 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- United States v. PhellisSupreme Court of the United States · 1921
- Weiss v. StearnSupreme Court of the United States · 1924
- Marr v. United StatesSupreme Court of the United States · 1925
- Cullinan v. Walker, Collector of Internal RevenueSupreme Court of the United States · 1923
4 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Grange Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1931
- Musser v. CommissionerUnited States Board of Tax Appeals · 1925
- Siegel v. CommissionerUnited States Board of Tax Appeals · 1926