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NORTH AMERICAN PHILIPS COMPANY, INC. v. COMMISSIONER

Docket No. 77299.

21 T.C.M. 1497 (1962)

T.C. Memo. 1962-284

North American Philips Company, Inc. v. Commissioner.

United States Tax Court.

Filed November 29, 1962.

Attorney(s) appearing for the Case

John D. Calhoun, Esq., George G. Tyler, Esq., 15 Broad St., New York, N. Y., and George S. Parlin, Jr., Esq., for the petitioner. Howard B. Sweig, Esq., and John J. O'Toole, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TRAIN, Judge:

Respondent determined a deficiency in petitioner's income tax for the calendar year 1954 in the amount of $1,335,740.06.

The issues for decision are as follows:

(1) Whether 279,000 shares of Reynolds Spring Company stock issued to petitioner in a taxable exchange had an ascertainable fair market value on December 29, 1954; and

(2) If the stock had an ascertainable fair market value...

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