Blumenthal v. Commissioner
United States Board of Tax Appeals
1. Opinion testimony of the taxpayer and an accountant that stock was not readily marketable or ready collateral for loans is held insufficient to overcome respondent's determination that shares received by taxpayer in exchange for assets had a fair market value when received equal to par, since respondent's determination finds support in contemporaneous sales to taxpayer and other incorporators of six-sevenths of the entire stock for cash at par, in the worth of the assets…
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1. Opinion testimony of the taxpayer and an accountant that stock was not readily marketable or ready collateral for loans is held insufficient to overcome respondent's determination that shares received by taxpayer in exchange for assets had a fair market value when received equal to par, since respondent's determination finds support in contemporaneous sales to taxpayer and other incorporators of six-sevenths of the entire stock for cash at par, in the worth of the assets as recognized by the incorporators in authorizing their purchase, and in the facts disclosed by the opening balance…
1Opinion of the Court
*902OPINION.
SteRni-iagen:
The petitioner presents only an issue of fact. He undertakes to prove that the $10,000 par value of shares received as stated in the facts had no market value when received. After examining the evidence, all of which was taken by deposition, we have found as a fact that the value of the shares was $10,000 as determined by respondent.
The shares were received at the time of organization. All of the corporation’s shares, aggregating $71,000 par value, were issued for $61,000 cash, the lease, the agency contract and certain undescribed services. The measure of each dollar of…
2Cited by14 opinions
- Security First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933
- Holmby Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Burns v. CommissionerUnited States Board of Tax Appeals · 1934
- Champlin v. CommissionerUnited States Board of Tax Appeals · 1933
- Buck v. United StatesDistrict Court, D. Delaware · 1957
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