Legal Opinion

Amalgamated Products Co. v. Commissioner

United States Board of Tax Appeals

Decided June 15, 1928No. Docket No. 11545PublishedCited by 1 opinion

(1) The ability, skill and experience of certain incorporators of a corporation which had no predecessor, held not to constitute good will. (2) Certain services and contracts held not to have been paid in for capital stock. (3) Respondent's action in reducing invested capital by the amount of taxes for previous years prorated from the due date of each installment approved.

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(1) The ability, skill and experience of certain incorporators of a corporation which had no predecessor, held not to constitute good will. (2) Certain services and contracts held not to have been paid in for capital stock. (3) Respondent's action in reducing invested capital by the amount of taxes for previous years prorated from the due date of each installment approved. Russel Wheel & Foundry Co.,3 B.T.A. 1168. (4) Refusal to compute profits taxes under sections 327 and 328 of the Revenue Act of 1918 approved.

1Opinion of the Court

*664OPINION.

Milliken:

The petition as amended raises three issues: (1) That the respondent erred in reducing petitioner’s invested capital by the amount of $76,000, representing tangible and intangible assets; (2) that he erred in reducing invested capital by the amount of taxes for previous years prorated from the date each installment was payable, and (3) that he erred in refusing to compute petitioner’s profits taxes under sections 327 and 328 of the Revenue Act of 1918.

In the original petition filed in this proceeding, petitioner asserted that the respondent erred in refusing to allow as…

2Cited by1 opinion

  1. Amalgamated Products Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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