Conkey v. Commissioner

Board of Tax Appeals

Conkey v. Commissioner

11 B.T.A. 888

CourtUnited States Board of Tax Appeals

DecidedApril 30, 1928

DocketDocket No. 6774

StatusPublished

This text of 11 B.T.A. 888 (Conkey v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Conkey v. Commissioner, 11 B.T.A. 888 (bta 1928).

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Opinion

[889]*889OPINION.

Love •

It is not necessary for us to discuss the various contentions advanced by the petitioner. It will be sufficient to observe that the intangibles in question were acquired by Conkey without any expenditure therefor and that there is no evidence as to their value, if any. at the time of transfer to petitioner. Section 331, Revenue Act of 1918. Obviously, therefore, the Commissiauer’s aetion in refusing to permit the inclusion in invested capital of any amount on account thereof must be approved.

Judgment will he entered for the respondent.

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[889]*889OPINION.

Love •

It is not necessary for us to discuss the various contentions advanced by the petitioner. It will be sufficient to observe that the intangibles in question were acquired by Conkey without any expenditure therefor and that there is no evidence as to their value, if any. at the time of transfer to petitioner. Section 331, Revenue Act of 1918. Obviously, therefore, the Commissiauer’s aetion in refusing to permit the inclusion in invested capital of any amount on account thereof must be approved.

Judgment will he entered for the respondent.

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Bluebook (online)

11 B.T.A. 888, Counsel Stack Legal Research, https://law.counselstack.com/opinion/conkey-v-commissioner-bta-1928.