Legal Opinion

Pierce v. Commissioner

United States Board of Tax Appeals

Decided April 3, 1931No. Docket No. 36457Published

1. The fair market value of shares of stock at the date of the death of the decedent determined. 2. Where a taxpayer in 1923 sold shares of stock for cash and bonds of another corporation, and the bonds have no readily realizable market value, the gain realized from the transaction is the excess of the cash received over the basis prescribed by the statute for computing gain or loss.

1Opinion of the Court

RICHARD DEZ. PIERCE AND ARTHUR M. BEALE, ADMINISTRATORS, C.T.A., OF THE ESTATE OF D. M. JAMES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Pierce v. Commissioner

Docket No. 36457.

United States Board of Tax Appeals

22 B.T.A. 1070; 1931 BTA LEXIS 2025;

April 3, 1931, Promulgated

1. The fair market value of shares of stock at the date of the death of the decedent determined.

2. Where a taxpayer in 1923 sold shares of stock for cash and bonds of another corporation, and the bonds have no readily realizable market value, the gain realized from the transaction is the excess of the cash…

2Cases cited15 opinions

  1. Vanderbilt v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Barnes v. CommissionerUnited States Board of Tax Appeals · 1927
  3. Montgomery Bros. & Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  4. Richards v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Jarecki Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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