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Full-Text Articles in Securities Law
Taxation-Income Tax-Dealings By Corporation In Its Own Stock, John N. Seaman
Taxation-Income Tax-Dealings By Corporation In Its Own Stock, John N. Seaman
Michigan Law Review
From 1921 to 1929, appellee corporation bought shares of its own stock, not for retirement, but to sustain the market, to increase the number of shareholders by resale in smaller blocks, and for other reasons. This stock was held as treasury stock. In 1929 it was sold by the corporation, at a profit. From 1920 to 1934 the Treasury Regulations exempted the proceeds of such a transaction from income tax, treating the purchase and sale as separate decrease and increase in the capital, and not as resulting in income. But in 1934 the regulation was changed, so as to tax …
Taxation -Income Tax - Profit On Sale Of Securities - Identification Of Shares Sold, Milton A. Kramer
Taxation -Income Tax - Profit On Sale Of Securities - Identification Of Shares Sold, Milton A. Kramer
Michigan Law Review
The taxpayer ordered his broker to sell certain shares of stock purchased in March, 1929, which were on deposit at a bank. He then ordered the bank to deliver a thousand shares from certificates numbered 80250 to 80258 inclusive, and 80264. It does not appear whether the instructions were written or oral. The bank, however, delivered by mistake certificates from another lot which had a considerably lower cost basis and had been held as collateral since 1925. The Board of Tax Appeals concluded that the shares delivered to the broker as represented by the certificates were the shares actually sold …