Ayer v. Commissioner
United States Board of Tax Appeals
1. Where under the laws of Michigan there was no provision for the extension of the life of a limited partnership association organized in 1891 for 20 years, held, a limited partnership association organized in 1908 for the purpose of taking over all the assets and liabilities of the old association is a new and distinct association (admittedly treated here as a corporation) rather than a mere continuation of the old, although there was no change in stockholders or the…
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1. Where under the laws of Michigan there was no provision for the extension of the life of a limited partnership association organized in 1891 for 20 years, held, a limited partnership association organized in 1908 for the purpose of taking over all the assets and liabilities of the old association is a new and distinct association (admittedly treated here as a corporation) rather than a mere continuation of the old, although there was no change in stockholders or the business then being carried on. 2. Where the evidence is clear that the value of the net assets of the old association in…
1Opinion of the Court
FREDERICK AYER, JR., ET AL., TRUSTEES UNDER INDENTURE OF TRUST EXECUTED BY FREDERICK AYER, DATED FEBRUARY 24, 1911, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ayer v. Commissioner
Docket No. 67766.
United States Board of Tax Appeals
37 B.T.A. 767; 1938 BTA LEXIS 990;
April 26, 1938, Promulgated
1. Where under the laws of Michigan there was no provision for the extension of the life of a limited partnership association organized in 1891 for 20 years, held, a limited partnership association organized in 1908 for the purpose of taking over all the assets and liabilities of the old…
2Cases cited14 opinions
- Koshland v. HelveringSupreme Court of the United States · 1936
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Kohlsaat v. MurphySupreme Court of the United States · 1878
- Taggart ex rel. Mason v. PerkinsMichigan Supreme Court · 1889
- Staver & Abbott Manufacturing Co. v. BlakeMichigan Supreme Court · 1896
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