Crowell v. Commissioner
United States Board of Tax Appeals
Additional compensation received by the petitioners for services rendered to a corporation in the form of shares of stock of the corporation held to constitute taxable income to the amount of their fair market value at the date of receipt.
1Opinion of the Court
*851OPINION.
Smith:
The deficiency notices to the petitioners upon which the petitions are based advised the petitioners that there was being added to the gross income reported by each petitioner $6,000, being the par value of the shares of stock received by them as additional compensation in 1923, since “it is held that the fact that the stock was closely held, and apparently no effort was made to dispose of same at any value, does not prove conclusively that it had no readily realizable market value.” The petitioners have sought by these proceedings to prove that the shares of stock received by…
2Cases cited4 opinions
- Richardson v. ShawSupreme Court of the United States · 1908
- Gorman v. LittlefieldSupreme Court of the United States · 1913
- Duel v. HollinsSupreme Court of the United States · 1916
- Caswell v. . PutnamNew York Court of Appeals · 1890
3Cited by8 opinions
- Mente & Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Bartlett v. CommissionerUnited States Board of Tax Appeals · 1933
- Shephard v. CommissionerUnited States Tax Court · 1963
- Bartlett v. CommissionerUnited States Board of Tax Appeals · 1933
- Crowell v. CommissionerUnited States Board of Tax Appeals · 1930
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