Legal Opinion

B. F. Sturtevant Co. v. Commissioner

United States Board of Tax Appeals

Decided June 30, 1932No. Docket Nos. 16007, 22743, 28576, 40824, 47304Published

1. Good will paid in to petitioner without consideration may not be included in invested capital. Herald Despatch Co.,4 B.T.A. 1096. 2. The evidence is insufficient to establish the March 1, 1913, value of patents and a license under which petitioner manufactured a patented article. 3. Petitioner held not entitled to deductions for amortization of war facilities the original cost of which was not borne by it, the only cost to petitioner, which was paid in 1919, being the…

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1. Good will paid in to petitioner without consideration may not be included in invested capital. Herald Despatch Co.,4 B.T.A. 1096. 2. The evidence is insufficient to establish the March 1, 1913, value of patents and a license under which petitioner manufactured a patented article. 3. Petitioner held not entitled to deductions for amortization of war facilities the original cost of which was not borne by it, the only cost to petitioner, which was paid in 1919, being the residual value for peace-time purposes. Held, further, that the claim for deductions was not timely filed.

1Opinion of the Court

B. F. STURTEVANT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

B. F. STURTEVANT COMPANY (OF CALIFORNIA), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

B. F. Sturtevant Co. v. Commissioner

Docket Nos. 16007, 22743, 28576, 40824, 47304.

United States Board of Tax Appeals

26 B.T.A. 598; 1932 BTA LEXIS 1286;

June 30, 1932, Promulgated

1. Good will paid in to petitioner without consideration may not be included in invested capital. Herald Despatch Co.,4 B.T.A. 1096.

2. The evidence is insufficient to establish the March 1, 1913, value of patents and a license under…

2Cases cited4 opinions

  1. Reinecke v. SpaldingSupreme Court of the United States · 1930
  2. Herald-Despatch Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  3. B. F. Sturtevant Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Lafayette-South Side Bank v. CommissionerUnited States Board of Tax Appeals · 1927

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