FX Systems Corp. v. Commissioner
United States Tax Court
Petitioner purchased certain assets for $ 200,000 in cash, a promissory note of $ 28,000, 500 shares of its series A preferred stock, and 500 shares of its series B preferred stock. Petitioner claimed a cost basis in the purchased assets in an amount equal to the fair market value thereof. Respondent, however, determined that petitioner's preferred stock could not be valued by reference to the value of the assets purchased.
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Petitioner purchased certain assets for $ 200,000 in cash, a promissory note of $ 28,000, 500 shares of its series A preferred stock, and 500 shares of its series B preferred stock. Petitioner claimed a cost basis in the purchased assets in an amount equal to the fair market value thereof. Respondent, however, determined that petitioner's preferred stock could not be valued by reference to the value of the assets purchased. Held, under the facts of the instant case, it cannot be presumed that the fair market value of the assets petitioner purchased is equal to the value of the consideration…
1Opinion of the Court
FX Systems Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
FX Systems Corp. v. Commissioner
Docket No. 2832-79
United States Tax Court
79 T.C. 957; 1982 U.S. Tax Ct. LEXIS 10; 79 T.C. No. 59;
December 1, 1982, Filed
Decision will be entered under Rule 155.
Petitioner purchased certain assets for $ 200,000 in cash, a promissory note of $ 28,000, 500 shares of its series A preferred stock, and 500 shares of its series B preferred stock. Petitioner claimed a cost basis in the purchased assets in an amount equal to the fair market value thereof. Respondent, however, determined…
2Cases cited8 opinions
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
- Seas Shipping Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Pittsburgh Terminal Corp. v. CommissionerUnited States Tax Court · 1973
- Moore-McCormack Lines, Inc. v. CommissionerUnited States Tax Court · 1965
- Simmonds Precision Prods. v. Comm'rUnited States Tax Court · 1980
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