Legal Opinion

Charles F. Hubbs & Co. v. Commissioner

United States Tax Court

Decided September 30, 1949No. Docket No. 19431Unpublished

Petitioner seeks to include in its equity invested capital for 1944 an amount in addition to that allowed by respondent representing what it claims to be the value of intangibles and good will acquired incident to the exchange of its capital stock for the assets of a sole proprietorship in 1908. Held, petitioner has failed to sustain its burden of proof and particularly has failed to prove the factors necessary to apply the formula set forth in A.R.M. 34.

1Opinion of the Court

Charles F. Hubbs & Company v. Commissioner.

Charles F. Hubbs & Co. v. Commissioner

Docket No. 19431.

United States Tax Court

1949 Tax Ct. Memo LEXIS 64; 8 T.C.M. (CCH) 903; T.C.M. (RIA) 49247;

September 30, 1949

Petitioner seeks to include in its equity invested capital for 1944 an amount in addition to that allowed by respondent representing what it claims to be the value of intangibles and good will acquired incident to the exchange of its capital stock for the assets of a sole proprietorship in 1908. Held, petitioner has failed to sustain its burden of proof and particularly has failed to prove…

2Cases cited2 opinions

  1. Burnet v. HoustonSupreme Court of the United States · 1931
  2. Dwight & Lloyd Sintering Co. v. CommissionerUnited States Board of Tax Appeals · 1924

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