Legal Opinion

Metropolitan Sec. Corp. v. Commissioner

United States Board of Tax Appeals

Decided March 18, 1930No. Docket No. 27956PublishedCited by 4 opinions

The petitioner held not liable for the taxes due from the Union Finance Co. for the years 1921 and 1922.

1Opinion of the Court

*302OPINION.

Marquette:

This proceeding involves additional taxes claimed by the respondent to be due from the Union Finance Co. for the years 1921 and 1922, which he proposes to assess against the petitioner as a transferee of that company, under authority of section 280 (a) (1) of the Revenue Act of 1926, which provides that:

Seo. 280. (a) The amounts oí the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same provisions and limitations as in the case of a deficiency in a tax imposed by this title,…

2Cases cited5 opinions

  1. American Railway Express Company v. CommonwealthCourt of Appeals of Kentucky (pre-1976) · 1920
  2. Hibernia Ins. v. St. Louis & New Orleans Transp. Co.U.S. Circuit Court for the District of Eastern Missouri · 1882
  3. Grenell v. Detroit Gas Co.Michigan Supreme Court · 1897
  4. McWilliams v. Excelsior Coal Co.Court of Appeals for the Eighth Circuit · 1924
  5. Swing v. American Glucose Co. & Glucose Sugar Refining Co.Appellate Court of Illinois · 1905

3Cited by4 opinions

  1. Eleanor H. Vendig, as Alleged Transferee of the Assets of Mavco Sales, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
  2. Gideon-Anderson Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Metropolitan Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1930
  4. Rauh v. CommissionerUnited States Board of Tax Appeals · 1931

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