Moore-McCormack Lines, Inc. v. Commissioner
United States Tax Court
1. Petitioner purchased 10 ships from a single seller by the issuance of 300,000 shares of its own previously unissued stock. The stock so issued constituted 13 percent of petitioner's outstanding stock thereafter. Two of the ships so purchased were immediately resold.
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1. Petitioner purchased 10 ships from a single seller by the issuance of 300,000 shares of its own previously unissued stock. The stock so issued constituted 13 percent of petitioner's outstanding stock thereafter. Two of the ships so purchased were immediately resold. Held, the basis to petitioner of the two ships resold is determined by the fair market value of the stock issued to purchase them; the fair market value of such stock was $ 30 per share. 2. Held: The cost basis, for purposes of computing depreciation of various other vessels, purchased in 1941, is the "statutory sales price" as…
1Opinion of the Court
Moore-McCormack Lines, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Moore-McCormack Lines, Inc. v. Commissioner
Docket No. 2887-62
United States Tax Court
44 T.C. 745; 1965 U.S. Tax Ct. LEXIS 37;
August 27, 1965, Filed
Decision will be entered under Rule 50.
1. Petitioner purchased 10 ships from a single seller by the issuance of 300,000 shares of its own previously unissued stock. The stock so issued constituted 13 percent of petitioner's outstanding stock thereafter. Two of the ships so purchased were immediately resold. Held, the basis to petitioner of the two ships resold is…
2Cases cited19 opinions
- Jane Perlman v. C. Russell Feldmann, Newport Steel CorporationCourt of Appeals for the Second Circuit · 1955
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
- Hazeltine Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1937
- Waterman Steamship Corp. v. United StatesSupreme Court of the United States · 1965
- Heiner v. CrosbyCourt of Appeals for the Third Circuit · 1928
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