Columbian Rope Co. v. Commissioner
United States Tax Court
1. Held, the undistributed income of a wholly owned Panama subsidiary formed by petitioner for valid business purposes is not includable in petitioner's taxable income in the years 1959, 1960, and 1961. 2. Held, further, petitioner is entitled to deduct in full the salaries paid in 1959, 1960, and 1961 to executive officers whose duties included the supervision of the affairs of a wholly owned Philippine subsidiary, and the salaries paid to certain clerical personnel whose…
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1. Held, the undistributed income of a wholly owned Panama subsidiary formed by petitioner for valid business purposes is not includable in petitioner's taxable income in the years 1959, 1960, and 1961. 2. Held, further, petitioner is entitled to deduct in full the salaries paid in 1959, 1960, and 1961 to executive officers whose duties included the supervision of the affairs of a wholly owned Philippine subsidiary, and the salaries paid to certain clerical personnel whose duties included handling purchases of raw materials from the Philippine subsidiary. 3. Held, further, petitioner is not…
1Opinion of the Court
Columbian Rope Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Columbian Rope Co. v. Commissioner
Docket Nos. 83757, 88062, 4548-62, 1718-63
United States Tax Court
42 T.C. 800; 1964 U.S. Tax Ct. LEXIS 68;
July 27, 1964, Filed
Decisions will be entered under Rule 50.
1. Held, the undistributed income of a wholly owned Panama subsidiary formed by petitioner for valid business purposes is not includable in petitioner's taxable income in the years 1959, 1960, and 1961.
2. Held, further, petitioner is entitled to deduct in full the salaries paid in 1959, 1960, and 1961 to executive…
2Cases cited12 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Boehm v. CommissionerSupreme Court of the United States · 1945
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