CORNING TRUST CO., EXECUTOR,
v.
COMMISSIONER OF INTERNAL REVENUE

U.S. | 1934-10-22
No. 405
293 U.S. 608 Supreme Court of the United States (1934) Positive Treatment
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  • Strauss v. Commissioner of Internal Revenue, 168 F.2d 441 (2d Cir. 1948)
    …t purchase. It is clear, of course, that apportionment is practicable, and consequently right, when made between two classes of stock each of which has an ascertainable fair market value. Houghton v. Commissioner, 2 Cir., 71 F. 2d 656, cert. denied 293 U.S. 608, 55 S.Ct. 124, 79 L.Ed. 699; see Taylor v. Commissioner, 2 Cir., 70 F. 2d 619, afiirmed, Helvering v. Taylor, 293 U.S. 507, 55 S.Ct. 287, 79 L.Ed. 623. And the case last mentioned shows that it is enough to defeat an apportionment to show that the o…

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