C. F. Hovey Co. v. Commissioner
United States Board of Tax Appeals
The value of good will paid in to a corporation for shares of capital stock determined.
1Opinion of the Court
*177OPINION.
Smith:
The only question presented by this appeal is the value for invested capital purposes of the good will of the C. F. Hovey Co. paid in to the taxpayer corporation in exchange for $200,000 qf its capital stock in September, 1914. The Commissioner has disallowed the claim of the taxpayer for any invested capital in respect of this asset, upon the ground that it has not proven any cash value for it; that for a period of five years prior to 1915 the taxpayer had operated at a small profit and operated at an actual loss in the year 1914. The taxpayer contends on the other hand that…
2Cases cited4 opinions
- von Au v. MagenheimerAppellate Division of the Supreme Court of the State of New York · 1908
- In re the Appraisal of the Estate of BallAppellate Division of the Supreme Court of the State of New York · 1914
- Macfadden v. JenkinsNorth Dakota Supreme Court · 1918
- Nelson v. HiattNebraska Supreme Court · 1893
3Cited by7 opinions
- Deseret Management Corporation v. United StatesUnited States Court of Federal Claims · 2013
- Fedders Corp. v. CommissionerUnited States Tax Court · 1979
- C. F. Hovey Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Estate of Kellar E. Watson v. CommissionerUnited States Tax Court · 1948
- Estate of Krafft v. CommissionerUnited States Tax Court · 1961
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