Wallis Tractor Co. v. Commissioner
United States Board of Tax Appeals
1. The par value of shares of stock issued for assets is not conclusive of the actual cash value or of the fair market price or value of such assets for the purpose of determining invested capital or profit or loss on sale or a reasonable amount for obsolescence. 2. In 1918 the Wallis Tractor Co. charged off its books of account an amount for obsolescence of drawings, blue prints, tracings, etc.
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1. The par value of shares of stock issued for assets is not conclusive of the actual cash value or of the fair market price or value of such assets for the purpose of determining invested capital or profit or loss on sale or a reasonable amount for obsolescence. 2. In 1918 the Wallis Tractor Co. charged off its books of account an amount for obsolescence of drawings, blue prints, tracings, etc. Held, that the actual cash value at the date of acquisition of such drawings, blue prints, tracings, etc., destroyed, is an allowable deduction from gross income. 3. In connection with the refinancing…
1Opinion of the Court
*996OPINION.
Smítii: These appeals come before this Board upon numerous assignments of error. In support of some of them the taxpayers have offered no evidence. At the hearing counsel for the Commissioner was permitted to amend his answer to the appeal of the Tractor Co. by alleging that the Commissioner erred in the computation of the invested capital for the year 1918 and that the correct invested capital for that year was $184,375 less than the amount shown on page 3 of the deficiency letter dated October 28, 1924. The net result of the amendment was to increase the deficiency in tax for the…
2Cases cited6 opinions
- United States v. PhellisSupreme Court of the United States · 1921
- Weiss v. StearnSupreme Court of the United States · 1924
- Marr v. United StatesSupreme Court of the United States · 1925
- Walter v. DuffyCourt of Appeals for the Third Circuit · 1923
- State ex rel. Van Dyke v. CaryWisconsin Supreme Court · 1923
1 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Johnson v. CommissionerUnited States Tax Court · 1980
- Simms v. CommissionerUnited States Board of Tax Appeals · 1933
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- George E. Johnson and Sylvia v. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Tex-Penn Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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