- 7 - Helvering v. Rankin, 295 U.S. 123, 127 (1935), where the Supreme Court described stock transfers of the taxpayer, Turner, stating: In none of these transactions did the broker deliver to Turner, or Turner to the broker, any stock certificate. No specific certificate of stock was ever bought or sold by the broker for Turner; and none was earmarked or allocated for him in any manner. The purchases and sales affecting his account were made through the medium of street certificates handled by the broker; and the transactions were evidenced solely by debits and credits in his account on the broker’s books * * * Petitioner’s assertion that she acquired the subject shares only upon Atlas’s issuance of a new certificate is further eroded by our finding that she was the one who in fact caused Atlas to issue a new certificate. Petitioner’s ability to cause the cancellation of certificate number 6278 and the issuance of certificate number 6980 is indicative of her ownership of the subject shares before November 28, 2001, the date on which that new certificate was issued. While petitioner points the Court to Rev. Rul. 81-158, 1981-1 C.B. 205, in search of a contrary holding, she construes that ruling too narrowly. Although both situations in the ruling do conclude that the transfer of stock occurs when the transfer agent is directed to reissue shares in the name of the new owner, the ruling does not conclude, as petitioner would have it be, that a transfer of stock may only occur when a transfer agent receives such a direction. Nor is it dispositive to our decision that certificate number 6278 contained the referenced restrictive legend. GivenPage: Previous 1 2 3 4 5 6 7 8 Next
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