Eaton v. Commissioner
United States Board of Tax Appeals
1. Petitioner, through a partnership of which he was a member, agreed to purchase from the stockholders of a corporation such shares of stock as should be offered within a certain period at $60 per share, although the market value of such shares was only $54. The agreement provided that he should receive 12,500 shares of the same kind of stock as compensation for undertaking and carrying out the purchase.
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1. Petitioner, through a partnership of which he was a member, agreed to purchase from the stockholders of a corporation such shares of stock as should be offered within a certain period at $60 per share, although the market value of such shares was only $54. The agreement provided that he should receive 12,500 shares of the same kind of stock as compensation for undertaking and carrying out the purchase. He purchased 79,687 shares and received the 12,500 shares, thus acquiring a total of 92,187 shares. The Commissioner added to his gross income the fair market value of the 12,500 shares.…
1Opinion of the Court
CYRUS S. EATON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Eaton v. Commissioner
Docket No. 86942.
United States Board of Tax Appeals
37 B.T.A. 715; 1938 BTA LEXIS 999;
April 15, 1938, Promulgated
1. Petitioner, through a partnership of which he was a member, agreed to purchase from the stockholders of a corporation such shares of stock as should be offered within a certain period at $60 per share, although the market value of such shares was only $54. The agreement provided that he should receive 12,500 shares of the same kind of stock as compensation for undertaking and carrying…
2Cases cited13 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Shwab v. DoyleSupreme Court of the United States · 1922
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
- Diescher v. CommissionerUnited States Board of Tax Appeals · 1937
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