Stacey Mfg. Co. v. Commissioner
United States Tax Court
1. Prior to March 1, 1913, petitioner made a distribution of its common stock upon common stock. Held, such distribution is not includible in petitioner's equity invested capital as a distribution of stock under section 718 (a) (3), 1939 Code. Owensboro Wagon Co., 18 T. C. 1107 (revd. 209 F. 2d 617), followed. 2. Held, petitioner is not entitled to include in its equity invested capital any amount as representing goodwill acquired from its predecessor partnership.
1Opinion of the Court
The Stacey Manufacturing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Stacey Mfg. Co. v. Commissioner
Docket No. 45706
United States Tax Court
24 T.C. 703; 1955 U.S. Tax Ct. LEXIS 138;
July 19, 1955, Filed
Decision will be entered under Rule 50.
1. Prior to March 1, 1913, petitioner made a distribution of its common stock upon common stock. Held, such distribution is not includible in petitioner's equity invested capital as a distribution of stock under section 718 (a) (3), 1939 Code. Owensboro Wagon Co., 18 T. C. 1107 (revd. 209 F. 2d 617), followed.
2. Held, petitioner is…
2Cases cited7 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Landesman-Hirschheimer Co. v. Commissioner of Int. Rev.Court of Appeals for the Sixth Circuit · 1930
- Owensboro Wagon Co. v. CommissionerUnited States Tax Court · 1952
- Owensboro Wagon Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- C. M. Hall Lamp Co. v. United StatesCourt of Appeals for the Sixth Circuit · 1953
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