Whitman, Ward & Lee Co. v. Commissioner

OPINION.

Matthews :

These proceedings, which were duly consolidated for hearing, are for the redetermination of deficiencies in income tax for 1928 asserted against the petitioners as follows: Whitman, Ward & Lee Co., $8,383.93; Arnold & Winsor Co., $960.50.

The issue presented is identical in each case, namely, whether the respondent erred in determining that the petitioner was taxable on the basis of a separate income tax return for the entire taxable year. Each petitioner is contending that it was a subsidiary of the General Foods Co. for a part of the year 1928, that its income for the…