Lafayette-South Side Bank v. Commissioner

1. The evidence in these proceedings is insufficient to show that control existed on the part of the petitioner sufficient to warrant affiliation during the period of liquidation of two other corporations the assets of which had been partially taken over by the petitioner. 2. Where stock is specifically issued for tangible assets and by the same agreement good will is to be turned over to the same corporation without an issuance of stock or the payment of any other consideration therefor, the principle laid down in St. Louis Screw Co.,2 B.T.A. 649, whereby an allocation of the stock between…