Mandel Bros. v. Commissioner
United States Board of Tax Appeals
1. Taxpayer exchanged its capital stock for a mixed aggregate of tangible and intangible property. Held, that the amount thereof should be allocated to the classes of assets according to their cash value at the time paid in, and that the taxpayer may include in invested capital as paid-in surplus the excess of the actual cash value of the tangibles over the par value of the capital stock allocated thereto and good will to the extent of the par value of the stock allocated…
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1. Taxpayer exchanged its capital stock for a mixed aggregate of tangible and intangible property. Held, that the amount thereof should be allocated to the classes of assets according to their cash value at the time paid in, and that the taxpayer may include in invested capital as paid-in surplus the excess of the actual cash value of the tangibles over the par value of the capital stock allocated thereto and good will to the extent of the par value of the stock allocated thereto, subject to the limitations. Appeal of St. Louis Screw Co.,2 B.T.A. 649. 2. A sum paid to a prior tenant by the…
1Opinion of the Court
APPEAL OF MANGEL BROTHERS.
Mandel Bros. v. Commissioner
Docket No. 1977.
United States Board of Tax Appeals
4 B.T.A. 341; 1926 BTA LEXIS 2307;
July 23, 1926, Decided.
1. Taxpayer exchanged its capital stock for a mixed aggregate of tangible and intangible property. Held, that the amount thereof should be allocated to the classes of assets according to their cash value at the time paid in, and that the taxpayer may include in invested capital as paid-in surplus the excess of the actual cash value of the tangibles over the par value of the capital stock allocated thereto and good will to the extent…
2Cases cited13 opinions
- Cleveland Home Brewing Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- Atterbury v. CommissionerUnited States Board of Tax Appeals · 1924
- Columbia Theatre Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- St. Louis Screw Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Beidler v. KingIllinois Supreme Court · 1904
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