Girard Trust Co. v. Commissioner

Board of Tax Appeals

Girard Trust Co. v. Commissioner

16 B.T.A. 308, 1929 BTA LEXIS 2607

CourtUnited States Board of Tax Appeals

DecidedApril 30, 1929

DocketDocket No. 23208.

StatusPublished

This text of 16 B.T.A. 308 (Girard Trust Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Girard Trust Co. v. Commissioner, 16 B.T.A. 308, 1929 BTA LEXIS 2607 (bta 1929).

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Opinion

[309]*309OPINION.

Akundell :

With the exception of the fact that a small amount of cash was involved in the transaction, the facts here do not differ from those of Richard T. Greene et al., Trustees, 15 B. T. A. 401, wherein we held that an exchange of securities held for investment for other securities likewise to be held for investment falls within section 202 (c) (1) of the Revenue Act of 1921, and such a transaction gives rise to neither a taxable gain nor a deductible loss. The cash adjustment of $2,328.19 incident to the exchange should be applied against, and used to reduce, the basis for determining gain or loss upon a subsequent sale of the property in the manner provided in section 202 (e) of the Revenue Act of 1921.

Reviewed by the Board.

Judgment toill he entered under Rule 50.

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[309]*309OPINION.

Akundell :

With the exception of the fact that a small amount of cash was involved in the transaction, the facts here do not differ from those of Richard T. Greene et al., Trustees, 15 B. T. A. 401, wherein we held that an exchange of securities held for investment for other securities likewise to be held for investment falls within section 202 (c) (1) of the Revenue Act of 1921, and such a transaction gives rise to neither a taxable gain nor a deductible loss. The cash adjustment of $2,328.19 incident to the exchange should be applied against, and used to reduce, the basis for determining gain or loss upon a subsequent sale of the property in the manner provided in section 202 (e) of the Revenue Act of 1921.

Reviewed by the Board.

Judgment toill he entered under Rule 50.

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Bluebook (online)

16 B.T.A. 308, 1929 BTA LEXIS 2607, Counsel Stack Legal Research, https://law.counselstack.com/opinion/girard-trust-co-v-commissioner-bta-1929.

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