Wells-Elkhorn Coal Co. v. Commissioner
United States Board of Tax Appeals
Waiver signed by a former president of a dissolved Kentucky corporation, who likewise became president of the successor corporation, held valid to extend the statutory period for assessment against such dissolved corporation.
1Opinion of the Court
*201OPINION.
Seawell:
The issue raised in the petition as to the constitutionality of section 280 of the Revenue Act of 1926 is fully answered by Phillips v. Commissioner, 283 U. S. 589, in which it was held that the section in question is not in violation of the Federal Constitution.
On the issue as to whether the petitioner is a transferee within the meaning of the aforementioned section, we do not think there can be any question as to the correctness of an affirmative answer thereto. In effect, what the petitioner says is that it was a purchaser in good faith for value and therefore comes within…
2Cases cited6 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Young v. FitchCourt of Appeals of Kentucky · 1918
- Ewald Iron Co. v. CommonwealthCourt of Appeals of Kentucky (pre-1976) · 1910
- Castle's Admr. v. Acrogen Coal Co.Court of Appeals of Kentucky · 1911
- Holliday v. Cornett, SheriffCourt of Appeals of Kentucky (pre-1976) · 1928
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- United States v. The Adams Building Company, Inc.Court of Appeals for the Sixth Circuit · 1976
- Morning Sun Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- American Equitable Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Newark Morning Ledger Co. v. CommissionerUnited States Board of Tax Appeals · 1939
- Wells-Elkhorn Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1932