Yakima Transfer & Storage Co. v. Commissioner
This text of 10 B.T.A. 244 (Yakima Transfer & Storage 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.
Opinion
[245]*245OPINION.
This proceeding involves a reorganization, to which section 331 of the Revenue Act of 1918 applies. Under the provisions of such section, the petitioner is entitled to take into its assets for invested capital only the cost thereof to the prior owners. The petitioner has adduced no evidence indicating that this was [246]*246not done by the respondent. The evidence adduced is not sufficient upon which to base any finding of fact indicating that respondent erred in the computation of depreciation.
The Board is without jurisdiction as to the years 1920 and 1921, as to which the respondent has asserted no deficiency. Appeal of Cornelius Cotton Mills, 4 B. T. A. 255.
Judgment will he entered for the respondent.
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Cite This Page — Counsel Stack
10 B.T.A. 244, 1928 BTA LEXIS 4155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yakima-transfer-storage-co-v-commissioner-bta-1928.