United States Board of Tax Appeals May 28, 1929, Docket No. 26555. (Wire Wheel Corp. v. Commissioner)

lead-opinion

*739OPINION.

SiefkiN :

As we view this case it is clear that the petitioner is not liable as a transferee under section 280 of the 1926 Act. Section 15 of the New York stock corporation law, under which the Houk .Manufacturing Co. and petitioner were merged in 1917, reads as follows:

Sec. 15. Merger.