Lloyd v. Commissioner
United States Board of Tax Appeals
The petitioner Hattie B. Young having executed a waiver on behalf of a dissolved corporation as secretary and having affixed the corporate seal thereon, the pres dent of the corporation having likewise signed the waiver on behalf of the corporation, is estopped from denying the validity of the waiver on the grounds that the subscribing officers were without authority at the time to act for the corporation.
Read the full summary
The petitioner Hattie B. Young having executed a waiver on behalf of a dissolved corporation as secretary and having affixed the corporate seal thereon, the pres dent of the corporation having likewise signed the waiver on behalf of the corporation, is estopped from denying the validity of the waiver on the grounds that the subscribing officers were without authority at the time to act for the corporation. Held, further, that in accordance with the stipulation filed by the parties the petitioner, Hattie B. Young, is liable as transferee for the unpaid taxes of the corporation.
1Opinion of the Court
OPINION.
Smith:
These proceedings involve the liability of the petitioners as transferees of the assets of the Wilson Investment Co. for unpaid income taxes of the company for the year 1924 in the amount of $2,158.33. The proceedings were consolidated for hearing. The essential facts and the question at issue are clearly set forth in the following stipulation filed by the parties:
1. The Wilson Investment Company, hereinafter referred to as the Company, was incorporated under the laws of the State of North Carolina on March 15, 1924.
2. The Company on October 27, 1925, duly filed in the office of…
2Cases cited4 opinions
- Kelly v. CalhounSupreme Court of the United States · 1878
- Lovett v. Steam Saw Mill Ass'nNew York Court of Chancery · 1836
- Hunt v. CommissionerUnited States Board of Tax Appeals · 1929
- Bowers v. HechtmanSupreme Court of Minnesota · 1891
3Cited by13 opinions
- Aurore B. Benoit, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
- Barbados 7 Ltd. v. CommmmissionerUnited States Tax Court · 1989
- Badger Materials, Inc. v. CommissionerUnited States Tax Court · 1963
- Field v. CommissionerUnited States Tax Court · 1959
- Estate of Maceo v. Comm'rUnited States Tax Court · 1964
8 more not listed; retrieve them via the Exa API.