# Rogers v. Commissioner > United States Board of Tax Appeals · June 25, 1928 · 12 B.T.A. 816 URL: https://www.frixlaw.com/law-library/cases/4488447 ## Case - **Full name:** ROBERT C. ROGERS, v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** June 25, 1928 - **Citations:** 12 B.T.A. 816; 1928 BTA LEXIS 3450 - **Precedential status:** Published - **Opinion:** Opinion of the court by Marquette - **Judges:** Marquette - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4488447 ## Opinion text *817 OPINION. Marquette: 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. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4488447. Public record. Not legal advice.