American Equitable Assurance Co. v. Commissioner
United States Board of Tax Appeals
1. TRANSFEREE LIABILITY. - Where in 1926 petitioner, a corporation, purchased certain assets from another corporation and as a part of the consideration therefor agreed to pay all taxes, Federal, state, or otherwise, if and when determined, for all years prior to the year 1926, and where respondent has determined a deficiency against the transferor corporation for the year 1922, and where the value of the property so transferred is far greater than the amount of the tax…
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1. TRANSFEREE LIABILITY. - Where in 1926 petitioner, a corporation, purchased certain assets from another corporation and as a part of the consideration therefor agreed to pay all taxes, Federal, state, or otherwise, if and when determined, for all years prior to the year 1926, and where respondent has determined a deficiency against the transferor corporation for the year 1922, and where the value of the property so transferred is far greater than the amount of the tax determined against the transferor, petitioner is liable as a transferee of property under the provisions of section 280,…
1Opinion of the Court
AMERICAN EQUITABLE ASSURANCE COMPANY OF NEW YORK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
American Equitable Assurance Co. v. Commissioner
Docket No. 44332.
United States Board of Tax Appeals
27 B.T.A. 247; 1932 BTA LEXIS 1094;
December 8, 1932, Promulgated
1. TRANSFEREE LIABILITY. - Where in 1926 petitioner, a corporation, purchased certain assets from another corporation and as a part of the consideration therefor agreed to pay all taxes, Federal, state, or otherwise, if and when determined, for all years prior to the year 1926, and where respondent has determined a…
2Cases cited17 opinions
- Hendrick v. LindsaySupreme Court of the United States · 1876
- Dean v. WalkerIllinois Supreme Court · 1882
- Ransdel v. MooreIndiana Supreme Court · 1899
- Tinkler v. SwaynieIndiana Supreme Court · 1880
- Chicago Title & Trust Co. v. Central Trust Co.Illinois Supreme Court · 1924
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