Legal Opinion

Coca-Cola Bottling Co. v. Commissioner

United States Tax Court

Decided July 31, 1951No. Docket Nos. 19828, 25082, 25083Published

1. Income -- Separate Entities -- Corporation and Partnership -- Section 22 (a). -- Sacramento Corporation (Coca-Cola Bottling Company of Sacramento, Ltd.), which had a sole and exclusive license to bottle and vend Coca-Cola in the Sacramento, California, area, granted to a partnership formed by its two principal stockholders, N. M. Sellers and Gladys Sellers, a sublicense to bottle and vend Coca-Cola in all of its territory for a period of 5 years.

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1. Income -- Separate Entities -- Corporation and Partnership -- Section 22 (a). -- Sacramento Corporation (Coca-Cola Bottling Company of Sacramento, Ltd.), which had a sole and exclusive license to bottle and vend Coca-Cola in the Sacramento, California, area, granted to a partnership formed by its two principal stockholders, N. M. Sellers and Gladys Sellers, a sublicense to bottle and vend Coca-Cola in all of its territory for a period of 5 years. The corporation also sold to the partnership at book value all of its operating equipment and all of its inventories of materials and supplies…

1Opinion of the Court

Coca-Cola Bottling Company of Sacramento, Ltd., Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent

Coca-Cola Bottling Co. v. Commissioner

Docket Nos. 19828, 25082, 25083

United States Tax Court

17 T.C. 101; 1951 U.S. Tax Ct. LEXIS 115;

July 31, 1951, Promulgated

Decisions will be entered under Rule 50.

1. Income -- Separate Entities -- Corporation and Partnership -- Section 22 (a). -- Sacramento Corporation (Coca-Cola Bottling Company of Sacramento, Ltd.), which had a sole and exclusive license to bottle and vend Coca-Cola in the Sacramento, California, area, granted to a…

Also in this document: Dissent.

2Cases cited29 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Commissioner v. TowerSupreme Court of the United States · 1946
  4. Higgins v. SmithSupreme Court of the United States · 1940
  5. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943

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