Bush Hog Mfg. Co. v. Commissioner
United States Tax Court
Bush Hog Manufacturing Co., Inc., all of whose stock was owned by four individuals, took over the manufacturing of Bush Hog cutting machines in 1953 and formed two sales companies to distribute the machines. The four stockholders acquired 78 percent of the stock of each of the sales companies and salesmen for the companies acquired the remaining 22 percent of the stock.
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Bush Hog Manufacturing Co., Inc., all of whose stock was owned by four individuals, took over the manufacturing of Bush Hog cutting machines in 1953 and formed two sales companies to distribute the machines. The four stockholders acquired 78 percent of the stock of each of the sales companies and salesmen for the companies acquired the remaining 22 percent of the stock. In 1957 as the business expanded six additional sales companies were formed and the sales territories of the eight sales companies were realigned according to geographic areas. The four stockholders of the manufacturing…
1Opinion of the Court
DeeNNEN, Judge:
In these consolidated cases respondent determined deficiencies in the income tax of petitioners for the fiscal years and in the amounts as follows:
Docket No. Petitioner Fiscal year ending Nov. 30-Deficiency
90260 Busk Hog Manufacturing Co., Inc.. 1957 1958 $120,785.20 136, 544.19
90261 Bush Hog Distributors, Inc_ 1957 1958 5, 600.70 5, 500.00
90262 Busk Hog of Mississippi, Inc. 19571 1958 831.33 3,475.11
90263 Busk Hog of Ba.-Ark., Inc_ 19571 1958 1,361.46 5,500.00
90264 Busk Hog Sales Co., Inc. 1957 1958 5,500.00 4,826.32
90265 Bush Hog-Central, Inc. 19571 1958 1.652.80 5,500.00
90266…
2Cases cited24 opinions
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