Legal Opinion

Atlas Tack Co. v. Commissioner

United States Board of Tax Appeals

Decided January 16, 1928No. Docket No. 4725Published

1. Petitioner issued its stock for the tangible and intangible assets of a predecessor business which had been unprofitable. Held, that the evidence does not establish that the intangible assets had any value for invested capital purposes in excess of that which has already been ascribed to them by including tangibles in invested capital at their value to a successfully operating concern. 2. Deductible allowance for exhaustion of power plant and machinery determined.

1Opinion of the Court

ATLAS TACK CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Atlas Tack Co. v. Commissioner

Docket No. 4725.

United States Board of Tax Appeals

9 B.T.A. 1322; 1928 BTA LEXIS 4248;

January 16, 1928, Promulgated

1. Petitioner issued its stock for the tangible and intangible assets of a predecessor business which had been unprofitable. Held, that the evidence does not establish that the intangible assets had any value for invested capital purposes in excess of that which has already been ascribed to them by including tangibles in invested capital at their value to a successfully…

2Cases cited1 opinion

  1. Atlas Tack Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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