Acme Manifolding Co. v. Commissioner
United States Board of Tax Appeals
1. Actual cash value of property acquired for cash and stock determined, and held that in computing invested capital the cash paid is to be allocated to the tangibles, and the stock to the tangibles in excess of the cash and to the intangibles in accordance with the rules announced in Evansville Courier,23 B.T.A. 862, and St. Louis Screw Co.,2 B.T.A. 649. 2. Respondent's finding of the current earnings available for the payment of dividends sustained in the absence of…
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1. Actual cash value of property acquired for cash and stock determined, and held that in computing invested capital the cash paid is to be allocated to the tangibles, and the stock to the tangibles in excess of the cash and to the intangibles in accordance with the rules announced in Evansville Courier,23 B.T.A. 862, and St. Louis Screw Co.,2 B.T.A. 649. 2. Respondent's finding of the current earnings available for the payment of dividends sustained in the absence of evidence proving the determination to be erroneous. 3. Special assessment denied. 4. Respondent's allowance for depreciation…
1Opinion of the Court
*431OPINION.
Aeundell :
The principal invested capital issue is whether certain assets acquired by the petitioner from the predecessor partnership have been included in invested capital at the full amount allowed by the statute. Good will is sought to be included at $50,000, this being the amount which the petitioner says it agreed to pay and did pay therefor in cash. An actual cash value of $92,079.50 is claimed for the plant at the date of acquisition, which is $42,079.50 greater than the value recorded on the books and allowed by the respondent. The right of the petitioner to include in invested…
2Cited by1 opinion
- Acme Manifolding Co. v. CommissionerUnited States Board of Tax Appeals · 1931