Legal Opinion

Musser v. Commissioner

United States Board of Tax Appeals

Decided October 27, 1925No. Docket No. 3046Published

The taxpayer owned certain shares of stock in a national bank, which, in 1919, was consolidated under a modification of its own charter with two other national banks and its name changed. Upon consolidation the taxpayer received 1 1/3 shares of stock in the consolidated bank for each share of stock owned previously.

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The taxpayer owned certain shares of stock in a national bank, which, in 1919, was consolidated under a modification of its own charter with two other national banks and its name changed. Upon consolidation the taxpayer received 1 1/3 shares of stock in the consolidated bank for each share of stock owned previously. Held, that the taxpayer exchanged certificates of stock in one national bank for a larger number of shares of stock in a consolidated national bank and that the taxpayer is liable to income tax in respect of the difference between the market value of the shares of stock received…

1Opinion of the Court

APPEAL OF R. D. MUSSER.

Musser v. Commissioner

Docket No. 3046.

United States Board of Tax Appeals

2 B.T.A. 1031; 1925 BTA LEXIS 2190;

October 27, 1925, Decided Submitted June 22, 1925.

The taxpayer owned certain shares of stock in a national bank, which, in 1919, was consolidated under a modification of its own charter with two other national banks and its name changed. Upon consolidation the taxpayer received 1 1/3 shares of stock in the consolidated bank for each share of stock owned previously. Held, that the taxpayer exchanged certificates of stock in one national bank for a larger number of…

2Cases cited1 opinion

  1. Musser v. CommissionerUnited States Board of Tax Appeals · 1925

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