National Piano Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. Evidence that instruments were signed by the Commissioner or a duly authorized agent, and evidence as to time of such signing held not necessary to constitute valid consents, and 1917 tax held not barred. 2. Since the petitioner was not organized until May 1, 1917, the respondent erred in including as its income for 1917 the income of the predecessor corporation from January 1, 1917, to May 1, 1917. 3. Upon the facts, held that the petitioner and another corporation were…
Read the full summary
1. Evidence that instruments were signed by the Commissioner or a duly authorized agent, and evidence as to time of such signing held not necessary to constitute valid consents, and 1917 tax held not barred. 2. Since the petitioner was not organized until May 1, 1917, the respondent erred in including as its income for 1917 the income of the predecessor corporation from January 1, 1917, to May 1, 1917. 3. Upon the facts, held that the petitioner and another corporation were affiliated. 4. In the absence of evidence as to the worthlessness in 1921 of the stock of a corporation which the…
1Opinion of the Court
*55OPINION.
Siepkin :
This proceeding raises questions as to—
1. Whether assessment and collection of taxes for the year 1917 are barred by the statute of limitations;
*562. The inclusion of income of the petitioner’s predecessor in the petitioner’s income for the year 1917;
3. Affiliation of petitioner and the Sparta Manufacturing Co.;
4. liespondent’s failure to deduct from taxable income in 1922 and |.923 an alleged net operating loss sustained by petitioner in 1921;
I 5. The deduction from income of petitioner of $22,948.76, which fcvas the amount of income tax of the National Automatic Music Co. Tor…
2Cases cited2 opinions
- Gonzales v. RossSupreme Court of the United States · 1887
- Griffin v. American Gold Mining Co.Court of Appeals for the Ninth Circuit · 1905
3Cited by1 opinion
- National Piano Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928