Albany Car Wheel Company, Inc. v. Commissioner of Internal Revenue

Petitioner, Albany Car Wheel Company, Inc., seeks review of a decision of the Tax Court, 40 T.C. 831 (1963), upholding the contention of the Commissioner that petitioner had overstated the cost basis of its assets. 26 U.S.C. § 1012 (1958).

Petitioner purchased the operating assets of a corporation engaged in the manufacture and sale of chilled iron wheels. Petitioner claims that the purchase cost included an obligation that it assumed under a union contract. The union contract in effect prior to the purchase provided that upon closing all or part of the plant, permanently or through…