Opinion

Automatic Sprinkler Co. v. Commissioner

  • 5 B.T.A. 479
  • 1926 BTA LEXIS 2853
Court
United States Board of Tax Appeals
Filed
Nov 12, 1926
Status
Published
On the bench
Littleton
Cited by
0 cases
Authority
More cited than 14.4%

The opinion

APPEAL OF AUTOMATIC SPRINKLER COMPANY OF AMERICA.

Automatic Sprinkler Co. v. Commissioner

Docket No. 4987.

United States Board of Tax Appeals

5 B.T.A. 479 ; 1926 BTA LEXIS 2853 ;

November 12, 1926 , Decided

*2853 Irving Smith, Jr., Esq., for the petitioner.

Thomas P. Dudley, Jr., Esq., for the Commissioner.

LITTLETON

*479 LITTLETON: This is an appeal from the determination of deficiencies for the years 1918 and 1919 in the amounts of $32,802.85 and $7,800.80, respectively, of which amounts approximately $2,100 is in dispute.

The controversy arises from the reduction by the Commissioner from $50,000 to $25,000 of invested capital, representing alleged value of patents and license agreements.

*480 FINDINGS OF FACT.

The taxpayer is a Delaware corporation with principal office in New York City. During the taxable years it was affiliated with the Sypho-Chemical Sprinkler Corporation. On February 6, 1916, the Sypho-Chemical Sprinkler Corporation acquired for $200,000 par value of its capital stock certain patents and license agreements covering a certain automatic fire extinguishment system, which patents and license agreements had an actual cash value at the time acquired for stock of $50,000.

Judgment will be entered for the petitioner upon the issue raised on 15 days' notice, under Rule 50.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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