Legal Opinion

Ajax Engineering Corp. v. Commissioner

United States Tax Court

Decided July 27, 1951No. Docket No. 24134Published

Taxable Year -- Beginning of. -- During a period prior to actual incorporation of petitioner certain business was transacted in the name of an existing corporation and petitioner's incorporators did not deal as agents for or transact business in the name and on behalf of the proposed corporation. Held, that petitioner's first taxable year began on the date of its incorporation.

1Opinion of the Court

Ajax Engineering Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Ajax Engineering Corp. v. Commissioner

Docket No. 24134

United States Tax Court

17 T.C. 87; 1951 U.S. Tax Ct. LEXIS 121;

July 27, 1951, Promulgated

Decision will be entered for the respondent.

Taxable Year -- Beginning of. -- During a period prior to actual incorporation of petitioner certain business was transacted in the name of an existing corporation and petitioner's incorporators did not deal as agents for or transact business in the name and on behalf of the proposed corporation. Held, that petitioner's…

2Cases cited3 opinions

  1. Camp Wolters Land Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1947
  2. Eveready Loan Co. v. CommissionerUnited States Tax Court · 1943
  3. Ajax Engineering Corp. v. CommissionerUnited States Tax Court · 1951

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