Legal Opinion

Bond Crown & Cork Co. v. Commissioner

United States Tax Court

Decided October 27, 1952No. Docket No. 40268Published

X corporation, a wholly owned subsidiary of Y corporation, filed applications for relief under section 722, I. R. C. Later X was dissolved and transferred all of its assets to Y in cancellation of its stock. Subsequently, the Commissioner duly mailed a notice to X disallowing the claims for refund applied for. Y filed a petition with this Court alleging error in such disallowance. Held, respondent's motion to dismiss for lack of jurisdiction granted. Section 732 (a), I. R. C.

1Opinion of the Court

Bond Crown & Cork Company, Successor in Reorganization to Cork-Tex Products Co., Petitioner, v. Commissioner of Internal Revenue, Respondent

Bond Crown & Cork Co. v. Commissioner

Docket No. 40268

United States Tax Court

19 T.C. 73; 1952 U.S. Tax Ct. LEXIS 66;

October 27, 1952, Promulgated

X corporation, a wholly owned subsidiary of Y corporation, filed applications for relief under section 722, I. R. C. Later X was dissolved and transferred all of its assets to Y in cancellation of its stock. Subsequently, the Commissioner duly mailed a notice to X disallowing the claims for refund applied for. Y…

Also in this document: Dissent.

2Cases cited10 opinions

  1. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  2. Bowman Hotel Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Roomberg v. United StatesDistrict Court, E.D. Pennsylvania · 1941
  4. Bond Crown & Cork Co. v. CommissionerUnited States Tax Court · 1952
  5. Interwoven Stocking Co. v. United StatesCourt of Appeals for the Third Circuit · 1944

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