California Brewing Asso. v. Commissioner
United States Board of Tax Appeals
1. A notice of deficiency for the calendar year 1936, held, in the circumstances, to be proper, notwithstanding the taxpayer was liquidated and dissolved on March 31, 1936. 2. A statement on the return that the taxpayer had been dissolved and that its parent company had acquired its assets in liquidation, held not to be a request for prompt assessment affecting the statute of limitation. 3. A corporation which in complete liquidation distributed all its assets, including its…
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1. A notice of deficiency for the calendar year 1936, held, in the circumstances, to be proper, notwithstanding the taxpayer was liquidated and dissolved on March 31, 1936. 2. A statement on the return that the taxpayer had been dissolved and that its parent company had acquired its assets in liquidation, held not to be a request for prompt assessment affecting the statute of limitation. 3. A corporation which in complete liquidation distributed all its assets, including its earnings and profits, held entitled to a dividends paid credit. Credit Alliance Corporation,42 B.T.A. 1020, followed.
1Opinion of the Court
CALIFORNIA BREWING ASSOCIATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ACME BREWERIES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
California Brewing Asso. v. Commissioner
Docket Nos. 101295, 101296.
United States Board of Tax Appeals
43 B.T.A. 721; 1941 BTA LEXIS 1462;
February 26, 1941, Promulgated
1. A notice of deficiency for the calendar year 1936, held, in the circumstances, to be proper, notwithstanding the taxpayer was liquidated and dissolved on March 31, 1936.
2. A statement on the return that the taxpayer had been dissolved and that its parent company…
2Cases cited4 opinions
- Smith v. CommissionerUnited States Board of Tax Appeals · 1932
- California Brewing Asso. v. CommissionerUnited States Board of Tax Appeals · 1941
- Credit Alliance Corp. v. CommissionerUnited States Board of Tax Appeals · 1940
- Pittsburgh & W. Va. Ry. v. CommissionerUnited States Board of Tax Appeals · 1935