Munson S.S. Line v. Commissioner
United States Board of Tax Appeals
A corporation owned all of the stock of eight subsidiary corporations, and operated in foreign trade vessels, owned by the latter, under charter parties and informal arrangements. It exercised, through stock ownership and identity of officers and directors, complete dominion and control of the vessels, collecting the revenues, paying the expenses, and allocating to the subsidiaries what it regarded as a fair share of the net earnings of the vessels.
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A corporation owned all of the stock of eight subsidiary corporations, and operated in foreign trade vessels, owned by the latter, under charter parties and informal arrangements. It exercised, through stock ownership and identity of officers and directors, complete dominion and control of the vessels, collecting the revenues, paying the expenses, and allocating to the subsidiaries what it regarded as a fair share of the net earnings of the vessels. Held, that it was not the "owner" of said vessels within section 23 of the Merchant Marine Act, and therefore was not entitled to deduct, in…
1Opinion of the Court
MUNSON STEAMSHIP LINE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Munson S.S. Line v. Commissioner
Docket No. 46601.
United States Board of Tax Appeals
30 B.T.A. 946; 1934 BTA LEXIS 1241;
June 19, 1934, Promulgated
A corporation owned all of the stock of eight subsidiary corporations, and operated in foreign trade vessels, owned by the latter, under charter parties and informal arrangements. It exercised, through stock ownership and identity of officers and directors, complete dominion and control of the vessels, collecting the revenues, paying the expenses, and allocating to the…
2Cases cited1 opinion
- Munson S.S. Line v. CommissionerUnited States Board of Tax Appeals · 1934