Briggs-Darby Constr. Co. v. Commissioner
United States Board of Tax Appeals
Petitioners issued all their capital stock to R. W. Briggs & Co. in exchange for a portion of the latter's machinery and equipment. The exchanges were made pursuant to contracts between R. W. Briggs & Co. and its superintendents whereby the superintendents were entitled to acquire a 45 percent interest in the business out of profits.
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Petitioners issued all their capital stock to R. W. Briggs & Co. in exchange for a portion of the latter's machinery and equipment. The exchanges were made pursuant to contracts between R. W. Briggs & Co. and its superintendents whereby the superintendents were entitled to acquire a 45 percent interest in the business out of profits. The depreciable assets were exchanged at a value in excess of their value on the books of R. W. Briggs & Co. Held, nontaxable exchanges occurred between R. W. Briggs & Co. and each of these petitioners, and the basis for depreciation is the same as it would be in…
1Opinion of the Court
BRIGGS-DARBY CONSTRUCTION CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
BRIGGS-KILLIAN COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
BRIGGS-SPENCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
W. M. THORNTON, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Briggs-Darby Constr. Co. v. Commissioner
Docket Nos. 90594, 90595, 90596, 90597.
United States Board of Tax Appeals
41 B.T.A. 136; 1940 BTA LEXIS 1232;
January 19, 1940, Promulgated
Petitioners issued all their capital stock to R. W. Briggs & Co. in exchange for a…
2Cases cited1 opinion
- Briggs-Darby Constr. Co. v. CommissionerUnited States Board of Tax Appeals · 1940