Vallejo Bus Co. v. Commissioner
United States Tax Court
The shareholders of a California corporation engaged in the operation of a bus line took over the corporation's business and assets on June 1, 1942, under a contract of purchase and sale, and continued operation of the business as partners.
Read the full summary
The shareholders of a California corporation engaged in the operation of a bus line took over the corporation's business and assets on June 1, 1942, under a contract of purchase and sale, and continued operation of the business as partners. By California statute the sale of a public utility is void until approved by the California Railroad Commission, which did not give its approval of this sale until September 15, 1942. The contract provided that the sale be subject to such approval and void if not approved. Income from operation of the business during the period June 1 to September 15,…
1Opinion of the Court
OPINION.
Johnson, Judge'.
The Commissioner determined against the Vallejo Bus Co. (hereinafter called petitioner corporation) a deficiency of $3,074.94 in declared value excess profits tax and a deficiency of $27,721.76 in excess profits tax for the year 1942, and asserted against the individual petitioners, Harry V. Soanes, Frank O. Bell, and Luther E. Gibson, as transferees of petitioner corporation’s assets, liability for these deficiencies. The individual petitioners concede liability for any deficiency due, but contend that the Commissioner erroneously included in the corporation’s 1942…
2Cases cited9 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
- Crum v. Mt. Shasta Power Corp.California Supreme Court · 1934
- Hanlon v. EshlemanCalifornia Supreme Court · 1915
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Universal Oil Products Co. v. Campbell (United States, Intervenor) (Two Cases)Court of Appeals for the Seventh Circuit · 1950
- W A G E, Inc. v. CommissionerUnited States Tax Court · 1952
- Ringmaster, Inc. v. CommissionerUnited States Tax Court · 1962
- Vallejo Bus Co. v. CommissionerUnited States Tax Court · 1948
- W A G E, Inc. v. CommissionerUnited States Tax Court · 1952