Legal Opinion

Ligon v. Commissioner

United States Board of Tax Appeals

Decided April 26, 1938No. Docket No. 84765Published

Stock pledged as collateral to secure petitioner's loan at a bank was sold for cash, subject to the lien of the bank, at a private sale for less than cost. At the time the collateral was under marginal requirements and the bank would not deliver the stock to the purchaser unless the amount for which the stock was sold was paid on petitioner's indebtedness or marginal requirements otherwise satisfied. Release of the stock was not a condition of the sale.

Read the full summary

Stock pledged as collateral to secure petitioner's loan at a bank was sold for cash, subject to the lien of the bank, at a private sale for less than cost. At the time the collateral was under marginal requirements and the bank would not deliver the stock to the purchaser unless the amount for which the stock was sold was paid on petitioner's indebtedness or marginal requirements otherwise satisfied. Release of the stock was not a condition of the sale. The stock was released to purchaser at his request in a subsequent year. The amount received for the stock was not paid and credited on the…

1Opinion of the Court

GROVER C. LIGON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ligon v. Commissioner

Docket No. 84765.

United States Board of Tax Appeals

37 B.T.A. 763; 1938 BTA LEXIS 989;

April 26, 1938, Promulgated

Stock pledged as collateral to secure petitioner's loan at a bank was sold for cash, subject to the lien of the bank, at a private sale for less than cost. At the time the collateral was under marginal requirements and the bank would not deliver the stock to the purchaser unless the amount for which the stock was sold was paid on petitioner's indebtedness or marginal requirements…

2Cases cited1 opinion

  1. Ligon v. CommissionerUnited States Board of Tax Appeals · 1938

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API