Legal Opinion

Bryan v. Commissioner

United States Tax Court

Decided May 7, 1951No. Docket No. 23928Published

Petitioner, in his income tax return for 1944, reported the sale of certain shares of stock but reported no gain on such sale claiming such shares were a gift. Held, that petitioner acquired the shares of stock for an adequate consideration and their basis for tax purposes, as determined by respondent, will not be disturbed.

1Opinion of the Court

Artis C. Bryan, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bryan v. Commissioner

Docket No. 23928

United States Tax Court

16 T.C. 972; 1951 U.S. Tax Ct. LEXIS 203;

May 7, 1951, Promulgated

Decision will be entered for respondent.

Petitioner, in his income tax return for 1944, reported the sale of certain shares of stock but reported no gain on such sale claiming such shares were a gift. Held, that petitioner acquired the shares of stock for an adequate consideration and their basis for tax purposes, as determined by respondent, will not be disturbed.

F. Robert Gilfoil, Jr., Esq., for…

2Cases cited9 opinions

  1. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  2. Bonham v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
  3. Continental Oil Co. v. JonesCourt of Appeals for the Tenth Circuit · 1949
  4. Bennet v. HelveringCourt of Appeals for the Second Circuit · 1943
  5. Commissioner of Internal Revenue v. FarrenCourt of Appeals for the Tenth Circuit · 1936

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