Legal Opinion

Carnie-Goudie Mfg. Co. v. Commissioner

United States Board of Tax Appeals

Decided January 21, 1930No. Docket Nos. 20074, 27095PublishedCited by 9 opinions

1. Evidence fails to show that a general retail store conducted by some of the officers of a corporation engaged in the manufacture and sale of specialized commodities is not a business entity separate and apart from the corporation. 2. Held, the petitioner and the Lux Fibre Co. were not affiliated corporations within the taxing statutes, during the year involved.

1Opinion of the Court

*897OPINION.

Lansdon :

At the hearing of these proceedings the respondent confessed error in reducing the petitioner’s invested capital for 1921 in the amount of $16,372.67, which should be restored thereto in the re-computation of any deficiency herein redetermined. Three other questions are presented for our determination, viz, (1) the status of the firm known as “ Goudie Brothers” as a business entity; (2) the relationship between the petitioner and the Lux Fibre Co. as to *898being affiliated corporations within the taxing statutes during the years in question; and (3) whether the delinquency…

2Cases cited5 opinions

  1. Bissell v. WardeSupreme Court of Missouri · 1895
  2. National Bank v. RomineeMissouri Court of Appeals · 1909
  3. Young v. SmithSupreme Court of Missouri · 1857
  4. Bowen v. EppersonMissouri Court of Appeals · 1909
  5. Stephenson v. CornellIndiana Supreme Court · 1858

3Cited by9 opinions

  1. N. H. Kelley v. CommissionerUnited States Tax Court · 1951
  2. United Aniline Co. v. CommissionerUnited States Tax Court · 1962
  3. Carnie-Goudie Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  4. Carnie-Goudie Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Hammonton Inv. & Mortg. Co. v. CommissionerUnited States Tax Court · 1959

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