Vonnegut Hardware Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner purchased all of the capital stock of another corporation and immediately proceeded to liquidate that corporation and take over its assets.
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1. Petitioner purchased all of the capital stock of another corporation and immediately proceeded to liquidate that corporation and take over its assets. Held, the fair market value of the assets is the "amount realized" upon distribution under sec. 202(c), Revenue Act of 1926, and petitioner is entitled to deduct from its income in 1925 the loss resulting from the complete liquidation of the corporation in that year. 2. Claimed loss for 1925 reduced in the amount of $10,150, the book value assigned to certain securities by the liquidating corporation, where no evidence was presented from…
1Opinion of the Court
*786OPINION.
Goodrich :
Respondent has disallowed as a deduction from income for 1925 the amount of $48,123.26, claimed by petitioner as a loss sustained upon the liquidation of the Lilly Hardware Co., the stock of which petitioner purchased at the initial price of $230,000, which was later reduced by cash refunds from the vendors totaling $31,867.83, and the transfer of various securities valued on the Lilly Co.’s books at $10,150. As counsel for respondent presented no evidence, made no statement of his case and filed no brief, the record makes no disclosure respecting the reason for respondent’s…
2Cases cited10 opinions
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- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Warner Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Riggs Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1929
- Babson v. CommissionerUnited States Board of Tax Appeals · 1933
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3Cited by1 opinion
- Vonnegut Hardware Co. v. CommissionerUnited States Board of Tax Appeals · 1933