Legal Opinion

Elliott-Granite Linen Corp. v. Commissioner

United States Board of Tax Appeals

Decided August 31, 1932No. Docket No. 48212Published

1. Petitioner held not entitled, under the provisions of section 206(b) of the Revenue Act of 1926, to deduct in 1926 the net losses of predecessor corporations for 1925. 2. In 1926 petitioner took over certain assets for which it issued its stock to the transferors. No question of gain or loss is involved.

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1. Petitioner held not entitled, under the provisions of section 206(b) of the Revenue Act of 1926, to deduct in 1926 the net losses of predecessor corporations for 1925. 2. In 1926 petitioner took over certain assets for which it issued its stock to the transferors. No question of gain or loss is involved. Held, that petitioner's depreciation basis with respect to said assets is the cost of the assets to the transferors, without diminution for prior accumulated depreciation up to the date of transfer. Held, further, no depreciation allowable with respect to assets whose cost had been fully…

1Opinion of the Court

ELLIOTT-GRANITE LINEN CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Elliott-Granite Linen Corp. v. Commissioner

Docket No. 48212.

United States Board of Tax Appeals

26 B.T.A. 936; 1932 BTA LEXIS 1221;

August 31, 1932, Promulgated

1. Petitioner held not entitled, under the provisions of section 206(b) of the Revenue Act of 1926, to deduct in 1926 the net losses of predecessor corporations for 1925.

2. In 1926 petitioner took over certain assets for which it issued its stock to the transferors. No question of gain or loss is involved. Held, that petitioner's depreciation…

2Cases cited1 opinion

  1. Elliott-Granite Linen Corp. v. CommissionerUnited States Board of Tax Appeals · 1932

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