Newberry v. Commissioner
United States Board of Tax Appeals
The Commissioner determined the fair market value of several blocks of 2,500 shares of stock at the time of their disposition by gift on the basis of the prices per share at which the stock sold on the stock exchange at the basic dates.
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The Commissioner determined the fair market value of several blocks of 2,500 shares of stock at the time of their disposition by gift on the basis of the prices per share at which the stock sold on the stock exchange at the basic dates. Held, that the fair market value of the blocks as thus determined is supported by the evidence, including (a) opinions of experts (arrived at upon study of market conditions, the financial record of the corporation, and a comparison of such corporation and its stock with similar corporations and their stock) that the exchange prices multiplied by the number of…
1Opinion of the Court
*1128OPINION.
Murdock :
The Commissioner conceded at the hearing that the petitioners are entitled to an exclusion of $5,000 for each of the twelve gifts involved in these proceedings. The only issue for decision by the Board is the value of each of the twelve gifts on the date that it was made. Each petitioner on each of three dates made two gifts. Each gift was of 2,500 shares of common stock of the J. J. Newberry Co. The Commissioner in determining the deficiencies placed a value on each gift by multiplying by 2,500 the unit price at which shares of the stock were currently selling on the New…
2Cases cited7 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Brooks-Scanlon Corp. v. United StatesSupreme Court of the United States · 1924
- Adams Express Co. v. Ohio State AuditorSupreme Court of the United States · 1897
- United States v. New River Collieries Co.Supreme Court of the United States · 1923
- Bingham's Administrator v. CommonwealthCourt of Appeals of Kentucky · 1922
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3Cited by17 opinions
- McShain v. CommissionerUnited States Tax Court · 1979
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- Andrews v. CommissionerUnited States Board of Tax Appeals · 1942
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