S. Feather Co. v. Commissioner
United States Board of Tax Appeals
The taxpayer, a New Jersey corporation, transferred all of its assets to its successor, a Delaware corporation of the same name, on July 1, 1918, and was dissolved soon thereafter. The Delaware corporation continued the business, and filed an income and profits tax return for the calendar year 1918, in which the gross income, deductions and credits of both corporations were reported in combined total amounts.
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The taxpayer, a New Jersey corporation, transferred all of its assets to its successor, a Delaware corporation of the same name, on July 1, 1918, and was dissolved soon thereafter. The Delaware corporation continued the business, and filed an income and profits tax return for the calendar year 1918, in which the gross income, deductions and credits of both corporations were reported in combined total amounts. Held, that said return was not in substantial compliance with the requirements of section 239, Revenue Act of 1918, and did not start the running of the period of limitations.
1Opinion of the Court
S. FEATHER COMPANY (DELAWARE CORPORATION), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
S. Feather Co. v. Commissioner
Docket No. 47171.
United States Board of Tax Appeals
28 B.T.A. 432; 1933 BTA LEXIS 1123;
June 20, 1933, Promulgated
The taxpayer, a New Jersey corporation, transferred all of its assets to its successor, a Delaware corporation of the same name, on July 1, 1918, and was dissolved soon thereafter. The Delaware corporation continued the business, and filed an income and profits tax return for the calendar year 1918, in which the gross income, deductions and credits of…
2Cases cited1 opinion
- S. Feather Co. v. CommissionerUnited States Board of Tax Appeals · 1933