Warren Nat. Bank v. Commissioner

BUFFINGTON, Circuit Judge.

The all-decisive question in this tax case is whether the profit of the taxpayer in the sale of certain stocks was realized in 1923 or 1924. This question and the pertinent facts bearing thereon were thus summarized by the Board of Tax Appeals: “The respondent maintains that the sale of capital stock by the decedent to Waibridge & Company was made in 1924, that the initial payment was $262,000 or approximately one-third of the purchase price and that the contract of November 16, 1923 (known as Exhibit A) was merely an agreement to sell the stock contingent upon…