First Seattle D. H. Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. A contract is not divisible where its terms are made interdependent and to be performed simultaneously. 2. Purchases and sales at par, of corporate preferred stocks, upon which the dividends are regularly paid, are evidence that the fair market value of the stocks is at least par.
1Opinion of the Court
FIRST SEATTLE DEXTER HORTON NATIONAL BANK AND HELEN KING BOOLE, EXECUTORS OF THE ESTATE OF GEORGE BOOLE, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
First Seattle D. H. Nat'l Bank v. Commissioner
Docket No. 47814.
United States Board of Tax Appeals
27 B.T.A. 1242; 1933 BTA LEXIS 1221;
April 26, 1933, Promulgated
1. A contract is not divisible where its terms are made interdependent and to be performed simultaneously.
2. Purchases and sales at par, of corporate preferred stocks, upon which the dividends are regularly paid, are evidence that the fair market value of the…
2Cases cited1 opinion
- First Seattle D. H. Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933