National Piano Mfg. Co. v. Commissioner
United States Board of Tax Appeals
1. Evidence that instruments were signed by the Commissioner or a duly authorized agent, and evidence as to time of such signing held not necessary to constitute valid consents, and 1917 tax held not barred. 2. Since the petitioner was not organized until May 1, 1917, the respondent erred in including as its income for 1917 the income of the predecessor corporation from January 1, 1917, to May 1, 1917. 3. Upon the facts, held that the petitioner and another corporation were…
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1. Evidence that instruments were signed by the Commissioner or a duly authorized agent, and evidence as to time of such signing held not necessary to constitute valid consents, and 1917 tax held not barred. 2. Since the petitioner was not organized until May 1, 1917, the respondent erred in including as its income for 1917 the income of the predecessor corporation from January 1, 1917, to May 1, 1917. 3. Upon the facts, held that the petitioner and another corporation were affiliated. 4. In the absence of evidence as to the worthlessness in 1921 of the stock of a corporation which the…
1Opinion of the Court
NATIONAL PIANO MANUFACTURING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
National Piano Mfg. Co. v. Commissioner
Docket Nos. 3333, 20486.
United States Board of Tax Appeals
11 B.T.A. 46; 1928 BTA LEXIS 3868;
March 20, 1928, Promulgated
1. Evidence that instruments were signed by the Commissioner or a duly authorized agent, and evidence as to time of such signing held not necessary to constitute valid consents, and 1917 tax held not barred.
2. Since the petitioner was not organized until May 1, 1917, the respondent erred in including as its income for 1917 the income of the…
2Cases cited3 opinions
- L. S. Ayers & Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- National Piano Manufacturing Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- National Piano Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928