Legal Opinion

Federal Oil Corp. v. Commissioner

United States Board of Tax Appeals

Decided November 5, 1931No. Docket No. 27855Published

Where the petitioner acquired all the assets of a taxpayer corporation and assumed its liabilities, exchanging therefor capital stock of a par value equal to the fair market value of the assets as determined by the parties, the petitioner is liable for any income or excess-profits taxes due from the taxpayer.

1Opinion of the Court

FEDERAL OIL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Federal Oil Corp. v. Commissioner

Docket No. 27855.

United States Board of Tax Appeals

24 B.T.A. 622; 1931 BTA LEXIS 1613;

November 5, 1931, Promulgated

Where the petitioner acquired all the assets of a taxpayer corporation and assumed its liabilities, exchanging therefor capital stock of a par value equal to the fair market value of the assets as determined by the parties, the petitioner is liable for any income or excess-profits taxes due from the taxpayer.

Phil D. Morelock, Esq., for the petitioner.

W. Frank…

2Cases cited1 opinion

  1. Federal Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1931

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API