C. G. Meaker Co. v. Commissioner
United States Tax Court
Meaker owned capital stock of Ivanhoe and for 16 years had leased certain warehouse premises owned by Ivanhoe. Meaker transferred the stock to Ivanhoe in exchange for a further 10- year lease commencing October 1, 1945. Respondent, in his notices of deficiency, valued the lease to Meaker at $ 45,900 and valued the stock to Ivanhoe at $ 130,000. At the hearing, respondent argued that the value of the lease and the stock were the same, viz., not less than $ 81,000 and not more…
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Meaker owned capital stock of Ivanhoe and for 16 years had leased certain warehouse premises owned by Ivanhoe. Meaker transferred the stock to Ivanhoe in exchange for a further 10- year lease commencing October 1, 1945. Respondent, in his notices of deficiency, valued the lease to Meaker at $ 45,900 and valued the stock to Ivanhoe at $ 130,000. At the hearing, respondent argued that the value of the lease and the stock were the same, viz., not less than $ 81,000 and not more than $ 82,332.27. Held, the value of the lease was $ 81,000 and the value of the stock was $ 62,718. Held, further, the…
1Opinion of the Court
OPINION.
Rice, Judge:
Subsection (a) of section 111 of the Internal Revenue Code provides that “The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis * * Subsection (b) provides that “the amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.”
Regulations 111, section 29.111-1 provide:
* * * Except as otherwise provided, the Internal Revenue Code regards as income or as loss sustained, the gain or loss…
2Cases cited5 opinions
- Tobey v. BarberNew York Supreme Court · 1809
- Commissioner of Internal Revenue v. SegallCourt of Appeals for the Sixth Circuit · 1940
- Commissioner of Internal Revenue v. LyonCourt of Appeals for the Ninth Circuit · 1938
- Elverson Corporation v. HelveringCourt of Appeals for the Second Circuit · 1941
- Trinity Corp. v. Commissioner of Internal Revenue.Court of Appeals for the Fifth Circuit · 1942
3Cited by8 opinions
- Larchfield Corp. v. United StatesDistrict Court, D. Connecticut · 1965
- FX Systems Corp. v. CommissionerUnited States Tax Court · 1982
- Regents Park PartnersUnited States Tax Court · 1992
- Stahl v. CommissionerUnited States Tax Court · 1987
- C. G. Meaker Co. v. CommissionerUnited States Tax Court · 1951
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