Legal Opinion

Parker v. Commissioner

United States Board of Tax Appeals

Decided January 11, 1929No. Docket Nos. 14186, 14953, 14954Published

1. A new corporation was formed by the consolidation of two other corporations. Upon the evidence, held that the stockholders of the old corporations received stock in the new corporations in exchange for stock of the old corporations in 1919 instead of 1918. 2. The common stock so received by petitioners held to have had no fair market value at the time received. 3. Held that, the burden of proof being upon the petitioners, it is not sufficient that they allege that the…

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1. A new corporation was formed by the consolidation of two other corporations. Upon the evidence, held that the stockholders of the old corporations received stock in the new corporations in exchange for stock of the old corporations in 1919 instead of 1918. 2. The common stock so received by petitioners held to have had no fair market value at the time received. 3. Held that, the burden of proof being upon the petitioners, it is not sufficient that they allege that the respondent made an incorrect determination, but they must affirmatively show what the correct determination should be. 4.…

1Opinion of the Court

HELEN PITTS PARKER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

GEORGE A. MOORE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

DIVIE B. DUFFIELD AND HELEN PITTS PARKER, EXECUTORS OF THE LAST WILL AND TESTAMENT OF ARTHUR M. PARKER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Parker v. Commissioner

Docket Nos. 14186, 14953, 14954.

United States Board of Tax Appeals

14 B.T.A. 1185; 1929 BTA LEXIS 2972;

January 11, 1929, Promulgated

1. A new corporation was formed by the consolidation of two other corporations. Upon the evidence, held that the…

2Cases cited1 opinion

  1. Parker v. CommissionerUnited States Board of Tax Appeals · 1929

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