Fostoria Milling & Grain Co. v. Commissioner
United States Board of Tax Appeals
TRANSFEREE - LIABILITY - SECTION 280, REVENUE ACT OF 1926. - A taxpayer sustained losses in 1921 and 1922 rendering it insolvent. In 1923 it conveyed all of its assets to petitioner, a new corporation organized by certain of its stockholders, together with other parties not previously identified with it, the consideration of the sale being the assumption by petitioner of certain specified debts of the taxpayer and being all of its then known liabilities.
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TRANSFEREE - LIABILITY - SECTION 280, REVENUE ACT OF 1926. - A taxpayer sustained losses in 1921 and 1922 rendering it insolvent. In 1923 it conveyed all of its assets to petitioner, a new corporation organized by certain of its stockholders, together with other parties not previously identified with it, the consideration of the sale being the assumption by petitioner of certain specified debts of the taxpayer and being all of its then known liabilities. In 1924 respondent determined a deficiency for the year 1920, later assessed same against the taxpayer, and in 1926 proposed assessment of…
1Opinion of the Court
FOSTORIA MILLING & GRAIN CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fostoria Milling & Grain Co. v. Commissioner
Docket No. 17191.
United States Board of Tax Appeals
11 B.T.A. 1401; 1928 BTA LEXIS 3631;
May 15, 1928, Promulgated
TRANSFEREE - LIABILITY - SECTION 280, REVENUE ACT OF 1926. - A taxpayer sustained losses in 1921 and 1922 rendering it insolvent. In 1923 it conveyed all of its assets to petitioner, a new corporation organized by certain of its stockholders, together with other parties not previously identified with it, the consideration of the sale being the…
2Cases cited49 opinions
- Northern Pacific Railway Co. v. BoydSupreme Court of the United States · 1913
- Wood v. DummerU.S. Circuit Court for the District of Maine · 1824
- Railroad Co. v. HowardSupreme Court of the United States · 1869
- American Railway Express Company v. CommonwealthCourt of Appeals of Kentucky (pre-1976) · 1920
- Hibernia Ins. v. St. Louis & New Orleans Transp. Co.U.S. Circuit Court for the District of Eastern Missouri · 1882
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