United Carbon Co. v. Commissioner of Internal Revenue

' SOPER, Circuit Judge.

The question presented in this case involving income taxes is whether the basis for computing depreciation and depletion allowances' on exhaustible assets acquired' from certain transferors by the taxpaying corporation in exchange for its capital stock is the fair market value of the assets at the time of acquisition, or the cost thereof to the transferors. The basis upon which depletion, exhaustion, wear and tear, and obsolescence are allowed by statute is the same as is provided for the purpose of determining the gain or loss upon the sale or other disposition of the…