Ayer v. Commissioner
United States Board of Tax Appeals
1. The original cost of stock is not necessarily the basis for determining profit or loss upon a sale. 2. Where the Commissioner determined that the original cost of stock had been reduced by the exercise of stockholder's rights to subscribe to additional stock, which rights arose out of the ownership of such original stock, held, that petitioner has not established the computation to be incorrect by showing only the original cost of the stock.
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1. The original cost of stock is not necessarily the basis for determining profit or loss upon a sale. 2. Where the Commissioner determined that the original cost of stock had been reduced by the exercise of stockholder's rights to subscribe to additional stock, which rights arose out of the ownership of such original stock, held, that petitioner has not established the computation to be incorrect by showing only the original cost of the stock. Miles v. Safe Deposit & Trust Co.,259 U.S. 247.
1Opinion of the Court
FREDERICK AYER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ayer v. Commissioner
Docket No. 8184.
United States Board of Tax Appeals
6 B.T.A. 152; 1927 BTA LEXIS 3578;
February 18, 1927, Promulgated
1. The original cost of stock is not necessarily the basis for determining profit or loss upon a sale.
2. Where the Commissioner determined that the original cost of stock had been reduced by the exercise of stockholder's rights to subscribe to additional stock, which rights arose out of the ownership of such original stock, held, that petitioner has not established the computation to be…
2Cases cited2 opinions
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Ayer v. CommissionerUnited States Board of Tax Appeals · 1927