Old Colony Trust Co. v. Commissioner
United States Board of Tax Appeals
1. The Commissioner's determination that a contract to purchase stock had a readily realizable market value in the taxable year 1921, sustained. 2. Determination of the March 1, 1913, value of shares of stock of Commonwealth Shoe & Leather Co. sustained.
1Opinion of the Court
*1336OPINION.
Love :
The first question to be determined in this case is whether or not the Commissioner erred in including in the taxable gross income of Reed, who was on a cash receipts and disbursements basis, for the year 1921, the amount of $350,000 which he found to be the readily realizable market value in that year of the written contract dated March 31, 1921, evidencing the obligation of Jones to pay the balance of the purchase price of stock sold by Reed to Jones. The term “gross income” includes gains, profits and income derived from dealings in property, whether real or personal, growing…
2Cited by3 opinions
- J. W. Perry v. CommissionerUnited States Tax Court · 1945
- Kennedy v. CommissionerUnited States Board of Tax Appeals · 1929
- Old Colony Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1928