In 1915 petitioner and husband purchased property by the entirety for $13,000. Petitioner contributed 12 per cent of the purchase price and her husband the remaining 88 per cent. In 1924 the husband died, the property at that time having a market value of $40,000. In 1925 petitioner sold the property for this sum. Petitioner, in her income tax return for that year, computed the taxable profit by using the market value of the property at the time of her husband's death with respect to the 88 per cent representing the contribution of the husband to the purchase price. Held, that the 1915 value was to be taken as the basis for the whole of the property in computing the taxable profit. Lang v. Commissioner of Internal Revenue, 289 U.S. 109, 53 Sup. Ct. 534 (1933).

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