Legal Opinion

Western Union Tel. Co. v. Commissioner

United States Board of Tax Appeals

Decided December 8, 1932No. Docket Nos. 48955, 48956Published

1. The case of Gold & Stock Telegraph Co.,26 B.T.A. 914, followed on the question of income to the taxpayer. 2. The petitioner held liable as transferee. The taxpayer corporations many years ago parted with all of their property under a long term lease to the petitioner, which lease provided for a certain rental and provided further than this rental should be paid directly to the stockholders of the taxpayer.

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1. The case of Gold & Stock Telegraph Co.,26 B.T.A. 914, followed on the question of income to the taxpayer. 2. The petitioner held liable as transferee. The taxpayer corporations many years ago parted with all of their property under a long term lease to the petitioner, which lease provided for a certain rental and provided further than this rental should be paid directly to the stockholders of the taxpayer. The petitioner had been a stockholder of the taxpayer at least during the taxable year and thereafter. During those years the petitioner distributed a portion of the rent to those…

1Opinion of the Court

THE WESTERN UNION TELEGRAPH COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Western Union Tel. Co. v. Commissioner

Docket Nos. 48955, 48956.

United States Board of Tax Appeals

27 B.T.A. 265; 1932 BTA LEXIS 1097;

December 8, 1932, Promulgated

1. The case of Gold & Stock Telegraph Co.,26 B.T.A. 914, followed on the question of income to the taxpayer.

2. The petitioner held liable as transferee. The taxpayer corporations many years ago parted with all of their property under a long term lease to the petitioner, which lease provided for a certain rental and provided further than…

2Cases cited32 opinions

  1. Phillips v. CommissionerSupreme Court of the United States · 1931
  2. Louisville & Nashville Railroad v. MottleySupreme Court of the United States · 1911
  3. Knox v. LeeSupreme Court of the United States · 1871
  4. Hollins v. Brierfield Coal & Iron Co.Supreme Court of the United States · 1893
  5. Scovill v. ThayerSupreme Court of the United States · 1882

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