Fuller v. Commissioner
United States Board of Tax Appeals
BASIS OF COST OF STOCK RECEIVED IN NONTAXABLE EXCHANGE SPLITUP. - On September 3, 1929, petitioner was the holder of 54,054 shares of stock, $10 par value, in the Packard Motor Car Co. On that date he received in exchange for these shares 270,270 shares of stock, no par value, in the same company, representing a splitup of 5 for 1. In the taxable year 1930 the petitioner sold 25,000 shares of the 270,270 shares thus received.
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BASIS OF COST OF STOCK RECEIVED IN NONTAXABLE EXCHANGE SPLITUP. - On September 3, 1929, petitioner was the holder of 54,054 shares of stock, $10 par value, in the Packard Motor Car Co. On that date he received in exchange for these shares 270,270 shares of stock, no par value, in the same company, representing a splitup of 5 for 1. In the taxable year 1930 the petitioner sold 25,000 shares of the 270,270 shares thus received. Held, the basis for computing the gain on the sale is the average cost of each of the 270,270 shares received in exchange, according to the rule laid down in Christian…
1Opinion of the Court
*159OPINION".
Black :
From the foregoing findings of fact it will be seen that in the taxable year petitioner sold 40,000 shares of his holdings of Packard Motor Car Co. stock. Fifteen thousand shares were of a purchase made after the splitup of September 3, 1929. As to the profits on this block of 13,000 shares, there is no controversy. Of the 40,000 shares sold, 25,000 were acquired in the splitup, and it is concerning the taxable profit on these 25,000 shares that the controversy arises. Petitioner has sought by a method of bookkeeping to identify the 25,000 shares of stock in question with some…
2Cases cited3 opinions
- Von Gunten v. CommissionerUnited States Board of Tax Appeals · 1933
- Mickler Holding Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Oliver v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by3 opinions
- Concord Instruments Corp. v. CommissionerUnited States Tax Court · 1994
- Fuller v. CommissionerUnited States Board of Tax Appeals · 1934
- Wheeler v. CommissionerUnited States Board of Tax Appeals · 1935