Legal Opinion

Eastern Shares Corp. v. Commissioner

United States Board of Tax Appeals

Decided May 14, 1935No. Docket No. 69219Published

Where a corporation issued to its stockholders rights to subscribe to certain of its unissued stock on a basis of one new share for each two old shares held and such stock rights had a fair market value at the time of receipt by the stockholders, and petitioner failed to exercise the rights issued to it and allowed them to lapse and become worthless, held, petitioner is not entitled to a deductible loss by reason of the lapse of such rights.

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Where a corporation issued to its stockholders rights to subscribe to certain of its unissued stock on a basis of one new share for each two old shares held and such stock rights had a fair market value at the time of receipt by the stockholders, and petitioner failed to exercise the rights issued to it and allowed them to lapse and become worthless, held, petitioner is not entitled to a deductible loss by reason of the lapse of such rights. St. Louis Union trust Co. et al., Co-trustees,30 B.T.A. 370, followed.

1Opinion of the Court

EASTERN SHARES CORPORATION (FORMERLY PASSWALL CORPORATION), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Eastern Shares Corp. v. Commissioner

Docket No. 69219.

United States Board of Tax Appeals

32 B.T.A. 608; 1935 BTA LEXIS 923;

May 14, 1935, Promulgated

Where a corporation issued to its stockholders rights to subscribe to certain of its unissued stock on a basis of one new share for each two old shares held and such stock rights had a fair market value at the time of receipt by the stockholders, and petitioner failed to exercise the rights issued to it and allowed them to lapse…

2Cases cited2 opinions

  1. St. Louis Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Eastern Shares Corp. v. CommissionerUnited States Board of Tax Appeals · 1935

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