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.
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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
White Farm Equipment Company, a Delaware Corporation (Successor to Oliver Corporation, a Delaware Corporation), Petitioner v. Commissioner of Internal Revenue, Respondent; Amerada Hess Corporation, Successor by Merger of Hess Oil and Chemical Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
White Farm Equipment Co. v. Commissioner
Docket Nos. 4792-69, 5842-70, 1367-71
United States Tax Court
61 T.C. 189; 1973 U.S. Tax Ct. LEXIS 22; 61 T.C. No. 23;
November 14, 1973, Filed
Decisions will be entered under Rule 50.
On Oct. 31, 1960, W acquired O's farm equipment business in…
2Cases cited41 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
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