Vonnegut Hardware Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner purchased all of the capital stock of another corporation and immediately proceeded to liquidate that corporation and take over its assets.
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1. Petitioner purchased all of the capital stock of another corporation and immediately proceeded to liquidate that corporation and take over its assets. Held, the fair market value of the assets is the "amount realized" upon distribution under sec. 202(c), Revenue Act of 1926, and petitioner is entitled to deduct from its income in 1925 the loss resulting from the complete liquidation of the corporation in that year. 2. Claimed loss for 1925 reduced in the amount of $10,150, the book value assigned to certain securities by the liquidating corporation, where no evidence was presented from…
1Opinion of the Court
VONNEGUT HARDWARE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Vonnegut Hardware Co. v. Commissioner
Docket No. 44940.
United States Board of Tax Appeals
28 B.T.A. 784; 1933 BTA LEXIS 1070;
July 28, 1933, Promulgated
1. Petitioner purchased all of the capital stock of another corporation and immediately proceeded to liquidate that corporation and take over its assets. Held, the fair market value of the assets is the "amount realized" upon distribution under sec. 202(c), Revenue Act of 1926, and petitioner is entitled to deduct from its income in 1925 the loss resulting from…
2Cases cited11 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Warner Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Riggs Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1929
- Babson v. CommissionerUnited States Board of Tax Appeals · 1933
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