Legal Opinion

F. Tinker & Sons Co. v. Commissioner

United States Board of Tax Appeals

Decided March 17, 1925No. Docket No. 1101Published

1. Evidence held not to prove that the actual cash value of the assets of a predecessor partnership paid in to the taxpayer corpotion for $55,000 par value capital stock was in excess of $55,000. 2. A corporation which acquires property from a partnership and as a part of the consideration assumes certain specified liabilities of the partnership is not entitled to deduct from gross income in its tax return for 1918 an amount paid in liquidating an unrecorded and undetermined…

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1. Evidence held not to prove that the actual cash value of the assets of a predecessor partnership paid in to the taxpayer corpotion for $55,000 par value capital stock was in excess of $55,000. 2. A corporation which acquires property from a partnership and as a part of the consideration assumes certain specified liabilities of the partnership is not entitled to deduct from gross income in its tax return for 1918 an amount paid in liquidating an unrecorded and undetermined liability.

1Opinion of the Court

Appeal of F. TINKER & SONS CO.

F. Tinker & Sons Co. v. Commissioner

Docket No. 1101.

United States Board of Tax Appeals

1 B.T.A. 799; 1925 BTA LEXIS 2798;

March 17, 1925, decided Submitted February 2, 1925.

1. Evidence held not to prove that the actual cash value of the assets of a predecessor partnership paid in to the taxpayer corpotion for $55,000 par value capital stock was in excess of $55,000.

2. A corporation which acquires property from a partnership and as a part of the consideration assumes certain specified liabilities of the partnership is not entitled to deduct from gross income in its…

2Cases cited1 opinion

  1. F. Tinker & Sons Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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