Atlas Tack Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner issued its stock for the tangible and intangible assets of a predecessor business which had been unprofitable. Held, that the evidence does not establish that the intangible assets had any value for invested capital purposes in excess of that which has already been ascribed to them by including tangibles in invested capital at their value to a successfully operating concern. 2. Deductible allowance for exhaustion of power plant and machinery determined.
1Opinion of the Court
*1325OPINION.
Phillips :
The petitioner assigns as its first error the refusal of the Commissioner, in computing the actual cash value of property acquired for stock at organization for invested capital purposes, to allow any separate value for the intangible assets. The books of account of the predecessor corporation were no longer in existence at the time of the hearing and because of this and the lapse of time, the evidence as to what happened is necessarily incomplete. It appears that the predecessor corporation, the Atlas Tack Co. of Maine, was a consolidation of several companies manufacturing…
2Cited by2 opinions
- Atlas Tack Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Atlas Tack Co. v. CommissionerUnited States Board of Tax Appeals · 1928