Securities Co. of New Jersey v. Commissioner
United States Board of Tax Appeals
1. Petitioner received certain shares of stock during the taxable year which respondent has determined had a fair market value of 12 1/2 cents per share. Held, on all the evidence, that the stock had a fair market value when received of 12 1/2 cents per share. 2. Petitioner's board of directors duly resolved during the taxable year to set aside its net profits for that year to retire its bonded indebtedness.
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1. Petitioner received certain shares of stock during the taxable year which respondent has determined had a fair market value of 12 1/2 cents per share. Held, on all the evidence, that the stock had a fair market value when received of 12 1/2 cents per share. 2. Petitioner's board of directors duly resolved during the taxable year to set aside its net profits for that year to retire its bonded indebtedness. Accordingly, entries were made in its journal debiting to surplus and crediting a certain amount to a bond retirement account. During the taxable year petitioner set aside shares of stock…
1Opinion of the Court
*1052OPINION.
Smith:
In the determination of the deficiency the respondent included in the taxable income for 1937 “the fair market value of 18,018 shares of capital stock of New Jersey Realty Co. received during the taxable year 1937”, which value he “determined to be 12y2 cents a share at the time of receipt.”
In the petition it is alleged:
Respondent was in error in considering as a dividend tlie receipt by petitioner of 875 shares in reorganization, which respondent has otherwise officially held to have been a tax-free reorganization within the year 1937.
In the answer to the petition this…
2Cited by3 opinions
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- Securities Co. of New Jersey v. CommissionerUnited States Board of Tax Appeals · 1941