Clark v. Commissioner
United States Board of Tax Appeals
1. STOCK DIVIDEND - SEC. 201(f), REVENUE ACT OF 1926. - A distribution among shareholders in exchange for old common stock, of preferred stock and an increased amount of common stock, in the same proportion, so far as the record discloses, in which the old common stock was held, is a stock dividend, therefore non-taxable, and does not change the basis for determining gain upon later disposition of the stock received in such exchange.
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1. STOCK DIVIDEND - SEC. 201(f), REVENUE ACT OF 1926. - A distribution among shareholders in exchange for old common stock, of preferred stock and an increased amount of common stock, in the same proportion, so far as the record discloses, in which the old common stock was held, is a stock dividend, therefore non-taxable, and does not change the basis for determining gain upon later disposition of the stock received in such exchange. Pearl B. Brown, Executrix,26 B.T.A. 901, followed. 2. EXCHANGE OF STOCK FOR STOCK - SEC. 203(b)(2), REVENUE ACT OF 1926. - Upon the facts held, an exchange of…
1Opinion of the Court
OPINION.
Leech:
The petitioner, an individual residing at Camden, New Jersey, filed an income tax return for the calendar year 1928, in which she reported, inter alia, the receipt of $24,120 from the sale of Victor Talking Machine Co. stock, that the cost thereof was $5,580.50 and that the gain realized amounted to $18,539.50. The Commissioner determined that she received $46,917 for such stock, that the stock cost her $10,408.71 and that she realized a taxable gain of $36,508.29. The Commissioner increased petitioner’s income by the amount of $17,968.79 and determined the deficiency in…
2Cases cited9 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Erskine v. CommissionerUnited States Board of Tax Appeals · 1932
- Brown v. CommissionerUnited States Board of Tax Appeals · 1932
- Powel v. CommissionerUnited States Board of Tax Appeals · 1932
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Clark v. CommissionerUnited States Board of Tax Appeals · 1933
- Horrmann v. CommissionerUnited States Board of Tax Appeals · 1936
- Hudson v. CommissionerUnited States Board of Tax Appeals · 1939
- Kelly v. CommissionerUnited States Board of Tax Appeals · 1938
- Lashar v. CommissionerUnited States Board of Tax Appeals · 1936
1 more not listed; retrieve them via the Exa API.