Bartlett v. Commissioner
United States Board of Tax Appeals
1. Corporate stock received by a partnership as compensation for services rendered should be included in partnership net income at its fair market value when received. 2. In the circumstances disclosed the fair market value of rights to subscribe to stock of a different corporation from the one issuing the rights did not constitute a taxable dividend.
1Opinion of the Court
*287OPINION.
Lansdon:
The respondent has determined that the fair market value of the stock of the Consolidated Instrument Co. of America *288at the date received by the partnership is the amount to be included in computing partnership net income. The petitioners contend that its value at December 31, 1929, when it was distributed, is the amount on which the partners are taxable. In Old Colony Trust Co. et al., Administrators, 22 B.T.A. 1062, we held that the fair market value of stock received as compensation for services rendered constituted taxable income to the recipient when received. Article 53…
2Cases cited10 opinions
- United States v. PhellisSupreme Court of the United States · 1921
- Marr v. United StatesSupreme Court of the United States · 1925
- Cullinan v. Walker, Collector of Internal RevenueSupreme Court of the United States · 1923
- Rockefeller v. United StatesSupreme Court of the United States · 1921
- Peabody v. EisnerSupreme Court of the United States · 1918
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3Cited by1 opinion
- Bartlett v. CommissionerUnited States Board of Tax Appeals · 1933