Legal Opinion
Alvord v. Commissioner
United States Tax Court
Decided April 3, 1959No. Docket Nos. 62747, 64407Published
1Opinion of the Court
OPINION.
Black, Judge:
The question involved in these proceedings is whether the Commissioner was correct in including 95 per cent of the undistributed Supplement P net income of Hekor, a Canadian corporation, for the years 1951, 1953, and 1954,2 in the gross income of petitioner, a United States citizen, for those years.
The Commissioner’s determinations were made pursuant to Supplement P (secs. 331-340) 3 which generally taxes United States shareholders on their proportionate part of the undistributed Supplement P net income of a foreign personal holding company. A foreign personal holding…
2Cases cited7 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Marsman v. CommissionerUnited States Tax Court · 1952
- Eder v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- Eder v. CommissionerUnited States Board of Tax Appeals · 1942
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