White Farm Equipment Co. v. Commissioner
United States Tax Court
On Oct. 31, 1960, W acquired O's farm equipment business in exchange for, inter alia, 655,000 shares of W common stock. The agreement between W and O assigned a value to the stock which valuation had economic significance in the transaction and was reached by knowledgeable parties through arm's-length bargaining. O's loss on the sale of its farm equipment business and W's basis in such business are both determined by the fair market value of the stock.
Read the full summary
On Oct. 31, 1960, W acquired O's farm equipment business in exchange for, inter alia, 655,000 shares of W common stock. The agreement between W and O assigned a value to the stock which valuation had economic significance in the transaction and was reached by knowledgeable parties through arm's-length bargaining. O's loss on the sale of its farm equipment business and W's basis in such business are both determined by the fair market value of the stock. Held, such fair market value of the stock under the facts of this case is the value assigned to it by the parties, O having failed to adduce…
1Opinion of the Court
FORRESTER, Judge:
Respondent has determined the following income tax deficiencies:
[[Image here]]
In docket No. 1367-71 petitioner Amerada Hess has claimed an overpayment of income tax in the amount of $2,300,554. The issue for our decision is the valuation of 655,000 shares of White Motor Co. common stock which formed part of the consideration in an exchange in 1960 between predecessors of the petitioners.
FINDINGS OF FACT
Some of the facts are stipulated and are so found.
The original petitioner in docket No. 4792-69 was Oliver Corp. (New Oliver), a Delaware corporation whose principal office was…
2Cases cited40 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Schulz v. CommissionerCourt of Appeals for the Ninth Circuit · 1961
- Schmitz v. CommissionerUnited States Tax Court · 1968
35 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Amerada Hess Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1975
- Bankers Trust Co. v. United StatesUnited States Court of Claims · 1975
- Frizzelle Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Garwood v. CommissionerUnited States Tax Court · 1974
- Amerada Hess Corporation, Successor by Merger to Hess Oil & Chemical Corporation (J. D. Callendar Financial Vice-Pres.) v. Commissioner of Internal Revenue. Amerada Hess Corporation, Successor by Merger to Hess Oil & Chemical Corporation (Harold N. Bast, Vice-Pres.) v. Commissioner of Internal Revenue. White Farm Equipment Company, a Delaware Corporation (Successor to Oliver Corporation, a Delaware Corp.) v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1975
10 more not listed; retrieve them via the Exa API.