Legal Opinion

Shipley v. Commissioner

United States Tax Court

Decided October 31, 1951No. Docket No. 29339Published

Sale of corporate stock at nominal price held not to result in taxable loss, where only evidence of value in prior years is corporation's book figures which are shown not to have any relation to actual value. Frank C. Rand, 40 B. T. A. 233, affd. (C. A. 8) 116 F. 2d 929, certiorari denied 313 U.S. 594, followed. B. F. Edwards, 39 B. T. A. 735, distinguished.

1Opinion of the Court

Grant B. Shipley, Petitioner, v. Commissioner of Internal Revenue, Respondent

Shipley v. Commissioner

Docket No. 29339

United States Tax Court

17 T.C. 740; 1951 U.S. Tax Ct. LEXIS 48;

October 31, 1951, Promulgated

Decision will be entered for the respondent.

Sale of corporate stock at nominal price held not to result in taxable loss, where only evidence of value in prior years is corporation's book figures which are shown not to have any relation to actual value. Frank C. Rand, 40 B. T. A. 233, affd. (C. A. 8) 116 F. 2d 929, certiorari denied 313 U.S. 594, followed. B. F. Edwards, 39 B. T. A. 735,…

Also in this document: Concurrence.

2Cases cited2 opinions

  1. Rand v. HelveringCourt of Appeals for the Eighth Circuit · 1941
  2. Shipley v. CommissionerUnited States Tax Court · 1951

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