Ambassador Petroleum Co. v. Commissioner
United States Board of Tax Appeals
1. BASIS FOR GAIN OR LOSS - COST OF PROPERTY ACQUIRED FOR STOCK AND CASH. - Where a corporation issues its capital stock for property plus some cash, the cost of the property to the corporation is the fair market value of the stock plus the cash paid. Seymour Mfg.
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1. BASIS FOR GAIN OR LOSS - COST OF PROPERTY ACQUIRED FOR STOCK AND CASH. - Where a corporation issues its capital stock for property plus some cash, the cost of the property to the corporation is the fair market value of the stock plus the cash paid. Seymour Mfg. Co.,19 B.T.A. 1280, followed. 2. BASIC DATE FOR VALUING STOCK. - Where a corporation agrees in 1920 to issue its capital stock in part payment for property but does not actually issue the stock until 1923, the basic date for valuing the stock to determine the cost of the property is in 1920 when the obligation to issue the stock was…
1Opinion of the Court
*872OPINION.
Black :
We are asked to determine the amount of petitioner’s net loss, if any, for the taxable year 1924 which petitioner seeks to deduct from its net income for the year 1925, and the amount of depletion deductible from petitioner’s gross income for the year 1925, These are the only two issues in this proceeding.
The parties have stipulated that if petitioner sustained a loss on the abandonment of its leasehold interest in parcel A in excess of $23,817.11, then and in that event it sustained a net loss within the *873meaning of section 206 of tbe Revenue Act of 1924, in the amount of such…
2Cases cited8 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
- United States v. Dakota-Montana Oil Co.Supreme Court of the United States · 1933
- Mead Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Hanscom v. CommissionerUnited States Board of Tax Appeals · 1931
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3Cited by10 opinions
- Ambassador Petroleum Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1936
- Holmby Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Ambassador Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Ambassador Petroleum Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1936
- Hazeltine Corp. v. CommissionerUnited States Board of Tax Appeals · 1935
5 more not listed; retrieve them via the Exa API.