Evansville Courier v. Commissioner
United States Board of Tax Appeals
1. Petitioner's contention, that its income was overstated in the amount of $15,000, denied. 2. Petitioner acquired a mixture of tangible and intangible assets for its capital stock and cash. Held, that for the purpose of determining the amount of intangibles acquired for stock to be used in the application of the 25 per cent limitation on intangibles, the cash, in the absence of evidence to the contrary, should be considered as having been paid for the tangibles.
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1. Petitioner's contention, that its income was overstated in the amount of $15,000, denied. 2. Petitioner acquired a mixture of tangible and intangible assets for its capital stock and cash. Held, that for the purpose of determining the amount of intangibles acquired for stock to be used in the application of the 25 per cent limitation on intangibles, the cash, in the absence of evidence to the contrary, should be considered as having been paid for the tangibles. Petitioner's contention, that the cash should be allocated between the two classes of assets in proportion to their cash value…
1Opinion of the Court
THE EVANSVILLE COURIER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Evansville Courier v. Commissioner
Docket No. 29413.
United States Board of Tax Appeals
23 B.T.A. 862; 1931 BTA LEXIS 1808;
June 25, 1931, Promulgated
1. Petitioner's contention, that its income was overstated in the amount of $15,000, denied.
2. Petitioner acquired a mixture of tangible and intangible assets for its capital stock and cash. Held, that for the purpose of determining the amount of intangibles acquired for stock to be used in the application of the 25 per cent limitation on intangibles, the cash, in…
2Cases cited1 opinion
- Evansville Courier v. CommissionerUnited States Board of Tax Appeals · 1931