Parker v. Commissioner
United States Board of Tax Appeals
1. A new corporation was formed by the consolidation of two other corporations. Upon the evidence, held that the stockholders of the old corporations received stock in the new corporations in exchange for stock of the old corporations in 1919 instead of 1918. 2. The common stock so received by petitioners held to have had no fair market value at the time received. 3. Held that, the burden of proof being upon the petitioners, it is not sufficient that they allege that the…
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1. A new corporation was formed by the consolidation of two other corporations. Upon the evidence, held that the stockholders of the old corporations received stock in the new corporations in exchange for stock of the old corporations in 1919 instead of 1918. 2. The common stock so received by petitioners held to have had no fair market value at the time received. 3. Held that, the burden of proof being upon the petitioners, it is not sufficient that they allege that the respondent made an incorrect determination, but they must affirmatively show what the correct determination should be. 4.…
1Opinion of the Court
*1196OPINION.
Siefkin:
The respondent in his determination increased the amount representing income of Helen Pitts Parker from dividends upon stock of the Parker Estate Company, Ltd., by $5,547.84. Petitioner had reported as dividends from this source $21,000, but she actually received $21,615. The parties at the hearing agreed that the amount taken by the respondent was erroneous and that the petitioner is subject to normal and surtaxes on $21,615 instead of only surtaxes on $21,000. The respondent also increased the petitioner’s taxable income for the year 1919 by the amount of $117,700, claiming…
2Cited by3 opinions
- Long v. CommissionerUnited States Tax Court · 1979
- Long v. CommissionerUnited States Tax Court · 1979
- Parker v. CommissionerUnited States Board of Tax Appeals · 1929