Legal Opinion

Perfex Corp. v. Commissioner

United States Board of Tax Appeals

Decided November 23, 1932No. Docket No. 44581Published

Certain individuals and corporations agreed among themselves to cause the petitioner corporation to be organized and to have transferred to it the assets of another company, which was in receivership. The assets were sold at a judicial sale to one who purported to act on behalf of the corporation to be formed and the assets were transferred by the receiver directly to the petitioner. The petitioner ratified this action.

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Certain individuals and corporations agreed among themselves to cause the petitioner corporation to be organized and to have transferred to it the assets of another company, which was in receivership. The assets were sold at a judicial sale to one who purported to act on behalf of the corporation to be formed and the assets were transferred by the receiver directly to the petitioner. The petitioner ratified this action. Held, that the petitioner has not overcome the presumption in favor of the correctness of the respondent's determination that the sale was direct to the petitioner and that…

1Opinion of the Court

PERFEX CORPORATION (FORMERLY RACINE RADIATOR COMPANY), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Perfex Corp. v. Commissioner

Docket No. 44581.

United States Board of Tax Appeals

27 B.T.A. 120; 1932 BTA LEXIS 1123;

November 23, 1932, Promulgated

Certain individuals and corporations agreed among themselves to cause the petitioner corporation to be organized and to have transferred to it the assets of another company, which was in receivership. The assets were sold at a judicial sale to one who purported to act on behalf of the corporation to be formed and the assets were…

2Cases cited10 opinions

  1. Whitney v. WymanSupreme Court of the United States · 1880
  2. Andrews v. CommissionerUnited States Board of Tax Appeals · 1928
  3. Pratt v. Oshkosh Match Co.Wisconsin Supreme Court · 1895
  4. State v. SextonSouth Dakota Supreme Court · 1897
  5. In re Quality Shoe Shop, Inc.District Court, E.D. Pennsylvania · 1914

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