Philadelphia Steel & Iron Corp. v. Commissioner
United States Tax Court
1. Petitioner purchased, under a written Agreement of Sale, dated January 23, 1956, certain assets, including all machinery and equipment, and business of the Philadelphia Steel and Iron Company, effective as of January 1, 1956. Petitioner paid $472,232.46 for the assets in controversy. Under the Agreement of Sale $1.00 was designated for good will and the balance to depreciable property.
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1. Petitioner purchased, under a written Agreement of Sale, dated January 23, 1956, certain assets, including all machinery and equipment, and business of the Philadelphia Steel and Iron Company, effective as of January 1, 1956. Petitioner paid $472,232.46 for the assets in controversy. Under the Agreement of Sale $1.00 was designated for good will and the balance to depreciable property. Held: Of the total amount of $472,232.46 paid by petitioner for the purchase of the assets, both tangible and intangible, of the Philadelphia Steel and Iron Company, the sum of $294,967.76 represented the…
1Opinion of the Court
Philadelphia Steel & Iron Corporation v. Commissioner.
Philadelphia Steel & Iron Corp. v. Commissioner
Docket No. 91893.
United States Tax Court
T.C. Memo 1964-93; 1964 Tax Ct. Memo LEXIS 241; 23 T.C.M. (CCH) 558; T.C.M. (RIA) 64093;
April 13, 1964
1. Petitioner purchased, under a written Agreement of Sale, dated January 23, 1956, certain assets, including all machinery and equipment, and business of the Philadelphia Steel and Iron Company, effective as of January 1, 1956. Petitioner paid $472,232.46 for the assets in controversy. Under the Agreement of Sale $1.00 was designated for good will and…
2Cases cited28 opinions
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- Georgia Railway & Power Co. v. Railroad CommissionSupreme Court of the United States · 1923
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- In Re the Accounting of BrownNew York Court of Appeals · 1926
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