Allington v. Commissioner
United States Board of Tax Appeals
1. Where a corporation in liquidation distributes part of its assets pro rata in cancellation of a fixed percentage of its total outstanding stock, a stockholder claiming error in taxing the gain to him under the first in, first out rule, art. 58, Regulations 74, has the burden of producing evidence showing the identity of the shares canceled. 2. Where a stockholder, in such liquidation, surrenders certificates for separate lots of stock purchased at different times and at…
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1. Where a corporation in liquidation distributes part of its assets pro rata in cancellation of a fixed percentage of its total outstanding stock, a stockholder claiming error in taxing the gain to him under the first in, first out rule, art. 58, Regulations 74, has the burden of producing evidence showing the identity of the shares canceled. 2. Where a stockholder, in such liquidation, surrenders certificates for separate lots of stock purchased at different times and at different prices, and receives an initial liquidating dividend and new certificates for a fixed percentage of all the…
1Opinion of the Court
COURTENAY D. ALLINGTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
LESLIE E. ALLINGTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Allington v. Commissioner
Docket Nos. 53411, 53412.
United States Board of Tax Appeals
31 B.T.A. 421; 1934 BTA LEXIS 1095;
October 25, 1934, Promulgated
1. Where a corporation in liquidation distributes part of its assets pro rata in cancellation of a fixed percentage of its total outstanding stock, a stockholder claiming error in taxing the gain to him under the first in, first out rule, art. 58, Regulations 74, has the burden of…
2Cases cited10 opinions
- Towne v. McElligottDistrict Court, S.D. New York · 1921
- Stewart v. CommissionerUnited States Board of Tax Appeals · 1929
- Snyder v. CommissionerUnited States Board of Tax Appeals · 1930
- Stryker v. CommissionerUnited States Board of Tax Appeals · 1930
- Mickler Holding Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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