Coosa Land Co. v. Commissioner
United States Board of Tax Appeals
1. Fair market value of corporation stock acquired prior to March 1, 1913, determined. 2. Claim for credit on 1926 income tax obligation for the amount of an overassessment found for 1925 disallowed because of the statutory bar which petitioner failed to prove was avoided by the filing of a timely claim as required by section 284(a) and (b)(1) of the 1926 Act. 3. Petitioner's claim for a loss deductible from gross income in 1926 on its investment in Atlas Fertilizer…
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1. Fair market value of corporation stock acquired prior to March 1, 1913, determined. 2. Claim for credit on 1926 income tax obligation for the amount of an overassessment found for 1925 disallowed because of the statutory bar which petitioner failed to prove was avoided by the filing of a timely claim as required by section 284(a) and (b)(1) of the 1926 Act. 3. Petitioner's claim for a loss deductible from gross income in 1926 on its investment in Atlas Fertilizer Corporation stock denied, because of failure of proof showing the value of assets paid in for such stock. 4. A payment made by…
1Opinion of the Court
OPINION.
Lansdon :
The respondent determined income tax deficiencies against the petitioner, as shown below, which are disputed in these *390consolidated appeals. In amended answers the respondent now asks that two of these deficiencies be increased. The cases by docket number, with years to which they relate, and amounts in dispute, are as follows:
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Prior to March 1,1913, the petitioner acquired stock in a Canadian holding corporation, which was subsequently taken over by the Southeastern Power & Light Co. In that process the petitioner received the latter company’s stock in exchange…
2Cases cited13 opinions
- Shafpa Realty Corp. v. CommissionerUnited States Board of Tax Appeals · 1927
- D. N. & E. Walter & Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Vaughan v. CommissionerUnited States Board of Tax Appeals · 1929
- Barto Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Dixie Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1925
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3Cited by4 opinions
- Balsam Trust v. CommissionerUnited States Tax Court · 1944
- Coosa Land Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Keefe v. CommissionerUnited States Tax Court · 1953
- Transportation Serv. Assocs. v. CommissionerUnited States Tax Court · 1944