Security Trust Co. v. Commissioner
United States Board of Tax Appeals
Where a testator devised and bequeathed the residue of his estate to trustees, the trustees in this way acquired certain stock, and thereafter a liquidating dividend was paid in 1925 to the trustees on the stock, the proper basis upon which to compute the gain from the transaction to the trust is the fair market value of the stock at the death of the testator. Brewster v. Gage,280 U.S. 327.
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined a deficiency of $4,145,-635.41 in the income-tax liability .of the Horace E. Dodge Trust for the year 1925. The parties have entered into a stipulation, which is made a part hereof by reference. The liability for tax on all miscellaneous items as to which errors were assigned in the petition has been conceded by the petitioner in this stipulation. The sole issue now in controversy is as to the proper basis upon which to compute the taxable gain realized by the petitioner in 1925 by reason of the receipt of a liquidating dividend from the Dodge…
2Cases cited11 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- United States v. PhellisSupreme Court of the United States · 1921
- Taft v. BowersSupreme Court of the United States · 1929
- Wager v. . WagerNew York Court of Appeals · 1882
- United States v. JonesSupreme Court of the United States · 1915
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Evans v. CommissionerUnited States Board of Tax Appeals · 1934
- Roebling v. CommissionerUnited States Board of Tax Appeals · 1933
- McCahill v. CommissionerUnited States Board of Tax Appeals · 1934
- McGrath v. CommissionerUnited States Board of Tax Appeals · 1934
- Roosevelt v. CommissionerUnited States Board of Tax Appeals · 1933
3 more not listed; retrieve them via the Exa API.