Lafayette-South Side Bank v. Commissioner
United States Board of Tax Appeals
1. The evidence in these proceedings is insufficient to show that control existed on the part of the petitioner sufficient to warrant affiliation during the period of liquidation of two other corporations the assets of which had been partially taken over by the petitioner. 2. Where stock is specifically issued for tangible assets and by the same agreement good will is to be turned over to the same corporation without an issuance of stock or the payment of any other…
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1. The evidence in these proceedings is insufficient to show that control existed on the part of the petitioner sufficient to warrant affiliation during the period of liquidation of two other corporations the assets of which had been partially taken over by the petitioner. 2. Where stock is specifically issued for tangible assets and by the same agreement good will is to be turned over to the same corporation without an issuance of stock or the payment of any other consideration therefor, the principle laid down in St. Louis Screw Co.,2 B.T.A. 649, whereby an allocation of the stock between…
1Opinion of the Court
*1319OPINION.
Littleton :
Three issues are raised in these proceedings as follows:
1. Were tlie Lafayette Bank and the South Side Bank affiliated with the petitioner for 1919 and 1920?
2. Did the petitioner acquire intangible assets by the issuance of capital stock therefor at date of organization, and if so, what was its value at the date of such acquisition?
3. In the event the Board should hold that the petitioner did not acquire intangible assets by the issuance of capital stock therefor, is the petitioner entitled to a paid-in surplus on account of intangibles paid in as a result of its formation?
A…
2Cited by2 opinions
- B. F. Sturtevant Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Lafayette-South Side Bank v. CommissionerUnited States Board of Tax Appeals · 1927