Pierce Oil Corp. v. Commissioner
United States Board of Tax Appeals
1. Special assessment required: a. Invested capital can not be determined. b. A mixed aggregate of tangible and intangible properties was paid in for shares, cash, and obligations and an allocation can not be made. c.
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1. Special assessment required: a. Invested capital can not be determined. b. A mixed aggregate of tangible and intangible properties was paid in for shares, cash, and obligations and an allocation can not be made. c. Abnormal conditions of capital and income are prima facie indicated by large borrowings and valuable intangibles which may not be included in invested capital. 2. Seller's breach in 1920 of a contract made in 1919 to deliver oil, does not affect seller's 1920 income, if seller contests liability and defends suit, judgment going against it in 1923 and compromised in 1924 after…
1Opinion of the Court
PIERCE OIL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
PIERCE NAVIGATION COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
PIERCE PIPE LINE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Pierce Oil Corp. v. Commissioner
Docket Nos. 49702-49704.
United States Board of Tax Appeals
32 B.T.A. 403; 1935 BTA LEXIS 952;
April 17, 1935, Promulgated
1. Special assessment required:
a. Invested capital can not be determined.
b. A mixed aggregate of tangible and intangible properties was paid in for shares, cash, and obligations and an…
2Cases cited45 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Burnet v. HarmelSupreme Court of the United States · 1932
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Brown v. HelveringSupreme Court of the United States · 1934
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