Akers v. Commissioner

OPINION.

Disney, Judge-.

The contention of the petitioner under the first issue is that the corporation had no going-concern value or good will and, consequently, no amount was received by him for such an asset as a liquidating dividend upon the dissolution of the corporation. Upon brief the respondent contends that the “going business” received by petitioner had a value of not less than $55,719.75 in excess of the net tangible assets distributed to him. As proof .of the receipt of an asset as determined by him, respondent refers to the large annual earnings of the corporation, the net income…