Legal Opinion

Jaffee v. Commissioner

United States Board of Tax Appeals

Decided November 29, 1929No. Docket Nos. 26587-26590PublishedCited by 1 opinion

1. Petitioner held to be transferees of the assets of Schwartz & Jaffee, Inc., within the meaning of section 280 of the Revenue Act of 1926. 2. Henry Cappellini et al.,14 B.T.A. 1269, followed.

1Opinion of the Court

*373OPINION.

Akundell :

As set forth above we assume that the petitioners have abandoned the errors alleged as to the respondent’s computation of invested capital and his failure to compute the profits taxes of Schwartz & Jaffee, Inc., under the special assessment provisions, but if we are wrong in our assumption, we dispose of the alleged errors by affirming the respondent because of the lack of any evidence to support the petitioners’ claims.

At the hearing counsel for petitioners stated that he does not admit that the petitioners are transferees under section 280 of the Revenue Act of 1926.…

2Cited by1 opinion

  1. Jaffee v. CommissionerUnited States Board of Tax Appeals · 1929

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