Legal Opinion

Palmer v. Commissioner

United States Board of Tax Appeals

Decided April 30, 1935No. Docket No. 62652Published

1. In 1929 the petitioner received rights on shares of stock in two corporations, which he had held for more than two years, entitling him to purchase additional shares of stock in such corporations. He sold the rights and in his income tax return reported the net proceeds as income taxable as capital net gain.

Read the full summary

1. In 1929 the petitioner received rights on shares of stock in two corporations, which he had held for more than two years, entitling him to purchase additional shares of stock in such corporations. He sold the rights and in his income tax return reported the net proceeds as income taxable as capital net gain. Held, that the net proceeds are taxable as capital net gain. 2. In 1929 the petitioner received rights on shares of stock of the American Superpower Corporation entitling him to purchase shares of stock in other corporations owned by the American Superpower Corporation. The rights thus…

1Opinion of the Court

BRADLEY W. PALMER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Palmer v. Commissioner

Docket No. 62652.

United States Board of Tax Appeals

32 B.T.A. 550; 1935 BTA LEXIS 937;

April 30, 1935, Promulgated

1. In 1929 the petitioner received rights on shares of stock in two corporations, which he had held for more than two years, entitling him to purchase additional shares of stock in such corporations. He sold the rights and in his income tax return reported the net proceeds as income taxable as capital net gain. Held, that the net proceeds are taxable as capital net gain.

2. In 1929…

2Cases cited9 opinions

  1. Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
  2. Van Vorst v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Powel v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Everhart v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Harkness v. CommissionerUnited States Board of Tax Appeals · 1935

4 more not listed; retrieve them via the Exa API.

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

Powered by the Exa API