Davidson v. Commissioner
United States Board of Tax Appeals
As applied to sales through a brokerage account of shares of stock purchased at different times and at different prices the first in, first out rule is not applicable: (a) Where the seller ordered the broker to sell certain specified shares which had been issued to him and put up as collateral for a loan and in completion of the sale the seller delivered to the broker certificates for the identical shares. The certificates delivered to the broker identified the shares sold.
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As applied to sales through a brokerage account of shares of stock purchased at different times and at different prices the first in, first out rule is not applicable: (a) Where the seller ordered the broker to sell certain specified shares which had been issued to him and put up as collateral for a loan and in completion of the sale the seller delivered to the broker certificates for the identical shares. The certificates delivered to the broker identified the shares sold. (b) Where the seller ordered the broker to sell certain specified shares which had not been issued to the seller but…
1Opinion of the Court
JAMES E. DAVIDSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
EDITH L. DAVIDSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Davidson v. Commissioner
Docket Nos. 61741, 72904, 72905.
United States Board of Tax Appeals
34 B.T.A. 555; 1936 BTA LEXIS 683;
May 8, 1936, Promulgated
As applied to sales through a brokerage account of shares of stock purchased at different times and at different prices the first in, first out rule is not applicable:(a) Where the seller ordered the broker to sell certain specified shares which had been issued to him and put up as collateral…
2Cases cited4 opinions
- Helvering v. RankinSupreme Court of the United States · 1935
- Miller v. CommissionerUnited States Board of Tax Appeals · 1934
- McCarter v. CommissionerUnited States Board of Tax Appeals · 1936
- Davidson v. CommissionerUnited States Board of Tax Appeals · 1936