McMichael v. Commissioner
United States Board of Tax Appeals
The basis for determining gain or loss on the sale of stock of an insurance company which had originally been doing business as a mutual company, is the cost and not the value when acquired in 1914, regardless of what factors enter into the value.
1Opinion of the Court
*267OPINION.
Thammell: This appeal raises the question of the taxpayers’ gain in 1917, 1918 and 1919 from the sale of stock of the Merchants Life and Casualty Co. in 1917. The taxpayer contends that the stock was worth at least as much on March 1, 1913, as it was sold for in 1917, and that no income arose out of the transaction.
The Commissioner contends that the basis for determining gain is the cost of the stock to the taxpayer. The Merchants Life and *268Casualty Co. was organized under the laws of Minnesota in 1908 as a mutual insurance company. The taxpayer, with others, was active in the…
2Cited by6 opinions
- Edward Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Edward Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Everhart v. CommissionerUnited States Board of Tax Appeals · 1932
- McMichael v. CommissionerUnited States Board of Tax Appeals · 1926
- Taplin v. CommissionerUnited States Board of Tax Appeals · 1928
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