Premier Packing Co. v. Commissioner
United States Board of Tax Appeals
1. ASSETS EXCHANGED FOR STOCK. - Stock received by petitioner in exchange for assets held to have no fair market value in exdess of cost of such assets and consequently no taxable gain to accrue from the transaction. 2. LIMITATION - WAIVER - AUTHORITY TO SIGN. - A waiver executed by the secretary of petitioner corporation, who was also a director, on the facts held to be binding, as its execution was an incident of the adjustment of its income-tax matters, being handled for…
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1. ASSETS EXCHANGED FOR STOCK. - Stock received by petitioner in exchange for assets held to have no fair market value in exdess of cost of such assets and consequently no taxable gain to accrue from the transaction. 2. LIMITATION - WAIVER - AUTHORITY TO SIGN. - A waiver executed by the secretary of petitioner corporation, who was also a director, on the facts held to be binding, as its execution was an incident of the adjustment of its income-tax matters, being handled for the corporation by him, the facts being sufficient to raise the presumption of knowledge, and consequently of…
1Opinion of the Court
PREMIER PACKING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Premier Packing Co. v. Commissioner
Docket No. 10192.
United States Board of Tax Appeals
12 B.T.A. 637; 1928 BTA LEXIS 3487;
June 15, 1928, Promulgated
1. ASSETS EXCHANGED FOR STOCK. - Stock received by petitioner in exchange for assets held to have no fair market value in exdess of cost of such assets and consequently no taxable gain to accrue from the transaction.
2. LIMITATION - WAIVER - AUTHORITY TO SIGN. - A waiver executed by the secretary of petitioner corporation, who was also a director, on the facts held to…
2Cases cited5 opinions
- Walter v. DuffyCourt of Appeals for the Third Circuit · 1923
- Wallis Tractor Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Premier Packing Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Billings Credit Men's Ass'n v. BogertCourt of Appeals for the Ninth Circuit · 1924
- Welz & Zeuveck, Inc. v. CommissionerUnited States Board of Tax Appeals · 1928