Rev. Rul. 54-17

The taxpayer, as the term is employed in section 322 of the Internal Revenue Code, means the one against whom the taxes were assessed. Thus where a corporation, since liquidated by merger with a successor corporation, overpaid its Federal income taxes, a claim for refund or credit should be executed by the successor corporation in the name of, and on behalf of, the corporation which paid such taxes, followed by the name of the successor corporation. There must be filed with each claim proper evidence establishing the liquidation and succession. If the succession is a matter of public record, certificates of the secretaries of state or other public officials having custody of these records must be attached. If the succession is not a matter of public record (and only in such event) then all pertinent documents pertaining to such succession, properly certified by a notary public or other qualified officers of the corporation, must be attached to the claim.