San Joaquin Fruit & Inv. Co. v. Commissioner
United States Board of Tax Appeals
1. Where a deficiency notice is sent to a corporation and its transferee files a petition from the notice, designating itself as the successor of the transferor corporation through change of name only, the Board has jurisdiction to hear the proceeding.
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1. Where a deficiency notice is sent to a corporation and its transferee files a petition from the notice, designating itself as the successor of the transferor corporation through change of name only, the Board has jurisdiction to hear the proceeding. Burnet v. San Joaquin Fruit & Investment Co., 52 Fed.(2d) 123, followed. 2. Where property is acquired after February 28, 1913, by a lessee through the exercise of an option in the lease to purchase the leased property, the basis to the purchaser for invested capital, determining gains or losses on sales, and computing exhaustion on the assets…
1Opinion of the Court
SAN JOAQUIN FRUIT & INVESTMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
San Joaquin Fruit & Inv. Co. v. Commissioner
Docket Nos. 6989, 20801, 27038, 35835, 40407, 42726, 49317, 52253.
United States Board of Tax Appeals
28 B.T.A. 395; 1933 BTA LEXIS 1133;
June 15, 1933, Promulgated
1. Where a deficiency notice is sent to a corporation and its transferee files a petition from the notice, designating itself as the successor of the transferor corporation through change of name only, the Board has jurisdiction to hear the proceeding. Burnet v. San Joaquin Fruit & Investment…
2Cases cited20 opinions
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Richardson v. HardwickSupreme Court of the United States · 1882
- Smith v. BanghamCalifornia Supreme Court · 1909
- Peoples Street Ry. Co. v. SpencerSupreme Court of Pennsylvania · 1893
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