Legal Opinion

United States Trucking Corp. v. Commissioner

United States Board of Tax Appeals

Decided January 30, 1934No. Docket No. 50000Published

1. Held, that petitioner is liable at law as a transferee on its contract of assumption of all obligations of the taxpayer corporation, and that such contractual liability may be enforced by the remedy provided in section 280 of the Revenue Act of 1926. American Equitable Assurance Co. of New York,27 B.T.A. 247, affirmed by the Circuit Court of Appeals, Second Circuit, December 11, 1933. 2. Where a corporation sustained a net loss in 1923 and thereafter became affiliated…

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1. Held, that petitioner is liable at law as a transferee on its contract of assumption of all obligations of the taxpayer corporation, and that such contractual liability may be enforced by the remedy provided in section 280 of the Revenue Act of 1926. American Equitable Assurance Co. of New York,27 B.T.A. 247, affirmed by the Circuit Court of Appeals, Second Circuit, December 11, 1933. 2. Where a corporation sustained a net loss in 1923 and thereafter became affiliated with another corporation on March 31, 1924, and on or about June 5, 1924, transferred its assets to the taxpayer…

1Opinion of the Court

UNITED STATES TRUCKING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Trucking Corp. v. Commissioner

Docket No. 50000.

United States Board of Tax Appeals

29 B.T.A. 940; 1934 BTA LEXIS 1453;

January 30, 1934, Promulgated

1. Held, that petitioner is liable at law as a transferee on its contract of assumption of all obligations of the taxpayer corporation, and that such contractual liability may be enforced by the remedy provided in section 280 of the Revenue Act of 1926. American Equitable Assurance Co. of New York,27 B.T.A. 247, affirmed by the Circuit Court…

2Cases cited2 opinions

  1. American Equitable Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  2. United States Trucking Corp. v. CommissionerUnited States Board of Tax Appeals · 1934

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