Popular Library, Inc. v. Commissioner
United States Tax Court
1. Held, that where corporation B merged into corporation L and the latter then merged into petitioner, this Court has jurisdiction of the petition which petitioner filed for redetermination of income tax deficiencies determined against B; for as the result of said mergers, petitioner became directly and primarily liable for B's income tax liabilities. 2. Held, that unrestricted cash amounts which B, an accrual basis taxpayer, received in 1954 as prepayments for…
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1. Held, that where corporation B merged into corporation L and the latter then merged into petitioner, this Court has jurisdiction of the petition which petitioner filed for redetermination of income tax deficiencies determined against B; for as the result of said mergers, petitioner became directly and primarily liable for B's income tax liabilities. 2. Held, that unrestricted cash amounts which B, an accrual basis taxpayer, received in 1954 as prepayments for subscriptions to magazines to be issued and delivered in subsequent years, must be included in B's gross income for the year of…
1Opinion of the Court
PieRce, Judge:
The Commissioner determined deficiencies in the income taxes of Best Books, Inc., a New York corporation, for taxable periods and in amounts as follows:
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The notice of deficiency was issued in the name of Best Books, Inc.
The present petitioner, Popular Library, Inc., a New York corporation, filed the petition herein for redetermination of the above-mentioned deficiencies; and it therein stated that such action was taken by it for the following reasons:
A. As of December 30th, 1954 Best Books Inc. was merged into Literary Enterprises Inc., a New York corporation, which…
2Cases cited5 opinions
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Irvine v. . New York Edison Co.New York Court of Appeals · 1913
- Bowman Hotel Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
- Wire Wheel Corp. v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by13 opinions
- BJR Corp. v. CommissionerUnited States Tax Court · 1976
- James M. Pierce Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Turnbull, Inc. v. CommissionerUnited States Tax Court · 1964
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1985
- Barnett Banks v. CommissionerUnited States Tax Court · 1996
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