Cleveland v. Commissioner
United States Board of Tax Appeals
1. The liability notices herein were timely mailed under the provisions of section 275(a) and 311(b) of the Revenue Act of 1928. 2. Where a taxpayer has no assets at the date of the determination of a deficiency, the respondent, under section 311 of the Revenue Act of 1928, may proceed at once to collect the deficiency from stockholders who have acquired the assets of such taxpayer without consideration. 3. Amount of income which taxpayer realized from payments of an award…
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1. The liability notices herein were timely mailed under the provisions of section 275(a) and 311(b) of the Revenue Act of 1928. 2. Where a taxpayer has no assets at the date of the determination of a deficiency, the respondent, under section 311 of the Revenue Act of 1928, may proceed at once to collect the deficiency from stockholders who have acquired the assets of such taxpayer without consideration. 3. Amount of income which taxpayer realized from payments of an award to it by the Mixed Claims Commission, United States and Germany, determined. Marine Transport Co.,28 B.T.A. 566, followed.
1Opinion of the Court
W. W. CLEVELAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
E. D. FLYNN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MCINTYRE LUMBER & EXPORT COMPANY, PETITIONER, v. COMMISSIONER INTERNAL REVENUE, RESPONDENT.
Cleveland v. Commissioner
Docket Nos. 64585, 64586, 67860, 68238, 68239.
United States Board of Tax Appeals
28 B.T.A. 578; 1933 BTA LEXIS 1103;
June 28, 1933, Promulgated
1. The liability notices herein were timely mailed under the provisions of section 275(a) and 311(b) of the Revenue Act of 1928.
2. Where a taxpayer has no assets at the date of the…
2Cases cited2 opinions
- Cleveland v. CommissionerUnited States Board of Tax Appeals · 1933
- Marine Transport Co. v. CommissionerUnited States Board of Tax Appeals · 1933