Legal Opinion

Vallejo Bus Co. v. Commissioner

United States Tax Court

Decided January 23, 1948No. Docket Nos. 11046, 11043, 11044, 11045Published

The shareholders of a California corporation engaged in the operation of a bus line took over the corporation's business and assets on June 1, 1942, under a contract of purchase and sale, and continued operation of the business as partners.

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The shareholders of a California corporation engaged in the operation of a bus line took over the corporation's business and assets on June 1, 1942, under a contract of purchase and sale, and continued operation of the business as partners. By California statute the sale of a public utility is void until approved by the California Railroad Commission, which did not give its approval of this sale until September 15, 1942. The contract provided that the sale be subject to such approval and void if not approved. Income from operation of the business during the period June 1 to September 15,…

1Opinion of the Court

The Vallejo Bus Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. Harry V. Soanes, Petitioner, v. Commissioner of Internal Revenue, Respondent. Frank O. Bell, Petitioner, v. Commissioner of Internal Revenue, Respondent. Luther E. Gibson, Petitioner, v. Commissioner of Internal Revenue, Respondent

Vallejo Bus Co. v. Commissioner

Docket Nos. 11046, 11043, 11044, 11045

United States Tax Court

10 T.C. 131; 1948 U.S. Tax Ct. LEXIS 282;

January 23, 1948, Promulgated

Decisions will be entered for respondent.

The shareholders of a California corporation engaged in the operation of a bus…

2Cases cited10 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Commissioner v. WilcoxSupreme Court of the United States · 1946
  3. Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
  4. Crum v. Mt. Shasta Power Corp.California Supreme Court · 1934
  5. Hanlon v. EshlemanCalifornia Supreme Court · 1915

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