Rogers v. Commissioner
This text of 12 B.T.A. 816 (Rogers 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.
Opinion
[817]*817OPINION.
Regardless of the lack of formality attending the transfer of the assets of the Robert C. Rogers Co., Inc., to the petitioner on July 31, 1919, the action was, in our opinion, clearly sufficient to vest in the petitioner title to such assets subject to the corporation’s debts, and the corporation from that date was only an empty shell. It had no assets and engaged in no business. It follows that the corporation had no income during the periods August 1 to December 31,1919, and January 1 to August 18, 1920, and that the petitioner did not receive any liquidating dividends from the corporation in 1920.
Judgment will he entered wider Rule 50.
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Cite This Page — Counsel Stack
12 B.T.A. 816, 1928 BTA LEXIS 3450, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rogers-v-commissioner-bta-1928.