Legal Opinion

Winger v. Commissioner

United States Board of Tax Appeals

Decided April 12, 1934No. Docket Nos. 60330-60344PublishedCited by 2 opinions

On the evidence, held, that the liability of the petitioners, as transferees, under section 280, Revenue Act of 1926, is not barred under section 277(a)(4), Revenue Act of 1926, as amended by section 503, Revenue Act of 1928.

1Opinion of the Court

OPINION.

McMahon :

These are consolidated proceedings for the redetermi-nation of the liabilities of the petitioners, as transferees, under section 280 of the Revenue Act of 1926, in respect of a deficiency of $3,522.47 in income tax for the year 1927 of the Aero Oil Co., a dissolved corporation.

There is no controversy concerning the correctness of the deficiency determined by the respondent, and the petitioners concede they are transferees of the assets of the dissolved corporation, liable as such for its tax to the extent of the assets received by each, provided assessment and collection are…

2Cases cited2 opinions

  1. Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
  2. Esperson v. CommissionerUnited States Board of Tax Appeals · 1928

3Cited by2 opinions

  1. Puget Sound Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1937
  2. Winger v. CommissionerUnited States Board of Tax Appeals · 1934

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