UNITED STATES

v.

SELLERS

Citator

Cited By

• Hazeltine Corp. v. Commissioner of Internal Revenue, 89 F.2d 513 (3d Cir. 1937)
  …what willing purchasers pay to willing sellers on the open market, even though the assets of the corporation do not reflect such values. Appeal of Edwin M. Brown, 1 B. T. A. 502; Commissioner v. Robertson (C.C.A.) 75 F. (2d) 540, certiorari denied 295 U.S. 763, 55 S.Ct. 922, 79 L.Ed. 1705. It is true that if market sales are made under peculiar and unusual circumstances, such as sales of small lots, forced sales, and sales in a restricted market, they may not furnish evidence of fair market value. Heiner…
• Patent Button Co. v. Commissioner of Internal Revenue, 203 F.2d 479 (2d Cir. 1953)
  …cement or otherwise, must necessarily be compensation and cannot be what it [*482] purports to be: an outright transfer of the stock, with an option for its retransfer later. See Gardner-Denver Co. v. C. I. R., 7 Cir., 75 F. 2d 38, certiorari denied 295 U.S. 763; 55 S.Ct. 922, 79 L.Ed. 1705; Commercial Inv. Trust Corp. v. C. I. R., 28 B.T.A. 143, 151, affirmed Commercial Inv. Trust Corp. v. Helvering, 2 Cir., 74 F. 2d 1015. . When we turn to the evidence of the later dealings .between the parties upon whic…