St. Louis Screw Co. v. Commissioner
United States Board of Tax Appeals
A corporation in 1911 issued its entire capital stock as a part consideration for the assets of a going business, including tangibles, patents, and good will, and, as a further consideration therefor, assumed all of the outstanding liabilities, the tangibles alone having a cash value in excess of the par value of the capital stock plus the liabilities assumed and the patents and good will also each having a cash value: Held, that under the Revenue Act of 1917 that portion of…
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A corporation in 1911 issued its entire capital stock as a part consideration for the assets of a going business, including tangibles, patents, and good will, and, as a further consideration therefor, assumed all of the outstanding liabilities, the tangibles alone having a cash value in excess of the par value of the capital stock plus the liabilities assumed and the patents and good will also each having a cash value: Held, that under the Revenue Act of 1917 that portion of the total consideration consisting of the liabilities assumed by the corporation should be applied against the tangible…
1Opinion of the Court
*653OPINION.
Smith:
This appeal presents for determination the following questions:
(а) The cash value of two patents at the date of acquisition by the taxpayer, namely, April 25, 1911.
(б) The cash value of the good will of a business acquired by the taxpayer in exchange for shares of stock at April 25, 1911.(c) Whether the taxpayer is entitled to include in invested capital for the fiscal years ended June 30, 1917, June 30, 1918, and June 30, 1919, any part of the cash value of the patents and good will acquired at organization in 1911.(d) Whether the taxpayer is entitled to claim as a deduction…
2Cases cited2 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Union Metal Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1925
3Cited by14 opinions
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- Charles Rubens & Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Corning Glass Works v. CommissionerUnited States Board of Tax Appeals · 1927
- D. N. & E. Walter & Co. v. CommissionerUnited States Board of Tax Appeals · 1928
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