Ashton v. Commissioner
United States Board of Tax Appeals
TRANSFEREE LIABILITY - BURDEN OF PROOF - SECTION 602, REVENUE ACT OF 1928. - Where the Commissioner has asserted a liability against petitioner as the transferee of the assets of a corporate taxpayer and in his petition the petitioner alleges certain errors by the Commissioner in his determination of the tax against the corporation, and admits that he is a transferee of the assets of the corporation but makes no admission as to the value of assets received, or that he is…
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TRANSFEREE LIABILITY - BURDEN OF PROOF - SECTION 602, REVENUE ACT OF 1928. - Where the Commissioner has asserted a liability against petitioner as the transferee of the assets of a corporate taxpayer and in his petition the petitioner alleges certain errors by the Commissioner in his determination of the tax against the corporation, and admits that he is a transferee of the assets of the corporation but makes no admission as to the value of assets received, or that he is liable as transferee, such admission is not to be construed as an admission on the part of petitioner that he is liable as…
1Opinion of the Court
OPINION.
Black :
This case involves a deficiency in tax liability of $1,248.78 for the year 1923 proposed for assessment against the petitioner as transferee of the assets of the Ashton Dry Goods Co., of Rockford, Illinois.
The statement accompanying the deficiency letter contains the following :
In re: Mr. Willard H. Ashton, Fort Collins, Colorado. Under authority of Section 280 of the Revenue Act of 1926, there is proposed for assessment against you the amount of $1,248.78 constituting your liability as transferee of the assets of the Ashton Dry Goods Company, Rockford, Illinois, for unpaid…
2Cases cited5 opinions
- Keller v. CommissionerUnited States Board of Tax Appeals · 1930
- Vogelstein v. CommissionerUnited States Board of Tax Appeals · 1929
- Burdick v. CommissionerUnited States Board of Tax Appeals · 1931
- Wray v. CommissionerUnited States Board of Tax Appeals · 1931
- Temoyan v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by8 opinions
- Tilton v. CommissionerUnited States Tax Court · 1987
- Behr v. CommissionerUnited States Board of Tax Appeals · 1934
- Ashton v. CommissionerUnited States Board of Tax Appeals · 1933
- Gottlieb v. CommissionerUnited States Tax Court · 1953
- Hurlbut v. CommissionerUnited States Board of Tax Appeals · 1935
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