Bartlett v. Commissioner

*287OPINION.

Lansdon:

The respondent has determined that the fair market value of the stock of the Consolidated Instrument Co. of America *288at the date received by the partnership is the amount to be included in computing partnership net income. The petitioners contend that its value at December 31, 1929, when it was distributed, is the amount on which the partners are taxable. In Old Colony Trust Co. et al., Administrators, 22 B.T.A. 1062, we held that the fair market value of stock received as compensation for services rendered constituted taxable income to the recipient when received. Article 53…