Commissioner v. Oliver

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The respondent’s husband had acquired 2,948 shares of Standard Sanitary Manufacturing Company stock, by purchase and stock dividends, at an aggregate cost of $249,-573. In February, 1923, the par value of the stock was reduced from $100 to $25 and each share was exchanged for 4, thereby increasing his holdings from 2,948 to 11,-792 shares. In April, 1923, the respondent received 5,000 of these shares as a gift from her husband. In 1925, these were increased to 6,250 by a 25 per cent, stock…