Brown v. Commissioner of Corporations & Taxation

The complainant purchased shares of stock at various times between 1868 and 1904 at prices aggregating $4,600. The value of these shares on the first of January, 1916, was $1,470. They were sold in 1920 for $4,996.32. The question is whether the complainant lawfully was taxable for income on the difference between the cost and sale price or on the difference between the value on the first of January, 1916, and the sale price. The answer depends on the true meaning of art. 44 of the Amendment to the Constitution authorizing the income tax and the statutes imposing the income tax. The pertinent…