Ashton v. Commissioner
United States Board of Tax Appeals
TRANSFEREE LIABILITY - BURDEN OF PROOF - SECTION 602, REVENUE ACT OF 1928. - Where the Commissioner has asserted a liability against petitioner as the transferee of the assets of a corporate taxpayer and in his petition the petitioner alleges certain errors by the Commissioner in his determination of the tax against the corporation, and admits that he is a transferee of the assets of the corporation but makes no admission as to the value of assets received, or that he is…
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TRANSFEREE LIABILITY - BURDEN OF PROOF - SECTION 602, REVENUE ACT OF 1928. - Where the Commissioner has asserted a liability against petitioner as the transferee of the assets of a corporate taxpayer and in his petition the petitioner alleges certain errors by the Commissioner in his determination of the tax against the corporation, and admits that he is a transferee of the assets of the corporation but makes no admission as to the value of assets received, or that he is liable as transferee, such admission is not to be construed as an admission on the part of petitioner that he is liable as…
1Opinion of the Court
WILLARD H. ASHTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ashton v. Commissioner
Docket No. 39148.
United States Board of Tax Appeals
28 B.T.A. 582; 1933 BTA LEXIS 1104;
June 28, 1933, Promulgated
TRANSFEREE LIABILITY - BURDEN OF PROOF - SECTION 602, REVENUE ACT OF 1928. - Where the Commissioner has asserted a liability against petitioner as the transferee of the assets of a corporate taxpayer and in his petition the petitioner alleges certain errors by the Commissioner in his determination of the tax against the corporation, and admits that he is a transferee of the assets of…
2Cases cited2 opinions
- Vogelstein v. CommissionerUnited States Board of Tax Appeals · 1929
- Ashton v. CommissionerUnited States Board of Tax Appeals · 1933