Kansas City Pump Co. v. Commissioner

Board of Tax Appeals

Kansas City Pump Co. v. Commissioner

6 B.T.A. 938

CourtUnited States Board of Tax Appeals

DecidedApril 21, 1927

DocketDocket No. 8871

StatusPublished

This text of 6 B.T.A. 938 (Kansas City Pump Co. 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

Kansas City Pump Co. v. Commissioner, 6 B.T.A. 938 (bta 1927).

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Opinion

[940]*940OPINION.

Milliken:

This cause was submitted on the pleadings, and the findings of fact are those recited by petitioner in petition filed and which were admitted in answer filed by respondent. Is the petitioner entitled to the deduction claimed ?

In 1913, the debtor dissolved and its assets passed to the petitioner in satisfaction of its debts. Those assets consisted of merchandise, machinery, fixtures, and deeds of trust on Colorado property. The fair market value of the assets received by petitioner from its debtor in 1913 was capable of definite ascertainment, at least we presume so', for we have no evidence to the contrary. The loss resulting from the debts owed to petitioner by the Denver Pump & Plumbing Co. was sustained at the time the assets of the latter were transferred in satisfaction of its obligations. The remainder of the debt, not satisfied by the assets received, was a loss sustained in 1913.

Judgment will he entered for the resfondent.

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[940]*940OPINION.

Milliken:

This cause was submitted on the pleadings, and the findings of fact are those recited by petitioner in petition filed and which were admitted in answer filed by respondent. Is the petitioner entitled to the deduction claimed ?

In 1913, the debtor dissolved and its assets passed to the petitioner in satisfaction of its debts. Those assets consisted of merchandise, machinery, fixtures, and deeds of trust on Colorado property. The fair market value of the assets received by petitioner from its debtor in 1913 was capable of definite ascertainment, at least we presume so', for we have no evidence to the contrary. The loss resulting from the debts owed to petitioner by the Denver Pump & Plumbing Co. was sustained at the time the assets of the latter were transferred in satisfaction of its obligations. The remainder of the debt, not satisfied by the assets received, was a loss sustained in 1913.

Judgment will he entered for the resfondent.

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Bluebook (online)

6 B.T.A. 938, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kansas-city-pump-co-v-commissioner-bta-1927.