Legal Opinion

Hartford-Empire Co. v. Commissioner

United States Board of Tax Appeals

Decided May 20, 1932No. Docket Nos. 29958, 41736, 53600Published

1. Allowances for exhaustion of patent and patent applications, acquired by petitioner in a transaction by which basis in hands of original owner is carried over, should be computed upon the basis of value thereof as of March 1, 1913, which value was previously determined by this Board. 2. Petitioner not permitted to apply against its income for 1923 and 1924 a net loss sustained in 1922 by a predecessor corporation, still in existence, for the reason that petitioner is not…

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1. Allowances for exhaustion of patent and patent applications, acquired by petitioner in a transaction by which basis in hands of original owner is carried over, should be computed upon the basis of value thereof as of March 1, 1913, which value was previously determined by this Board. 2. Petitioner not permitted to apply against its income for 1923 and 1924 a net loss sustained in 1922 by a predecessor corporation, still in existence, for the reason that petitioner is not "the taxpayer" within the meaning of section 204(b), Revenue Act of 1921, and section 206(b), Revenue Act of 1924.

1Opinion of the Court

HARTFORD-EMPIRE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hartford-Empire Co. v. Commissioner

Docket Nos. 29958, 41736, 53600.

United States Board of Tax Appeals

26 B.T.A. 134; 1932 BTA LEXIS 1361;

May 20, 1932, Promulgated

1. Allowances for exhaustion of patent and patent applications, acquired by petitioner in a transaction by which basis in hands of original owner is carried over, should be computed upon the basis of value thereof as of March 1, 1913, which value was previously determined by this Board.

2. Petitioner not permitted to apply against its income for 1923…

2Cases cited1 opinion

  1. Hartford-Empire Co. v. CommissionerUnited States Board of Tax Appeals · 1932

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