Legal Opinion

Peerless Pattern Co. v. Commissioner

United States Board of Tax Appeals

Decided January 16, 1934No. Docket Nos. 54291, 59360, 59361Published

1. The same individual owned all the outstanding voting stock of one corporation in the years 1926, 1927, and 1928, and over 95 percent of the outstanding voting stock of a second corporation from October 18, 1926, during the remainder of that year and throughout 1927 and 1928. The two corporations filed returns on a separate basis for 1926. The aforesaid same individual became the owner of all the stock of a third corporation at the date of its organization, May 10, 1927,…

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1. The same individual owned all the outstanding voting stock of one corporation in the years 1926, 1927, and 1928, and over 95 percent of the outstanding voting stock of a second corporation from October 18, 1926, during the remainder of that year and throughout 1927 and 1928. The two corporations filed returns on a separate basis for 1926. The aforesaid same individual became the owner of all the stock of a third corporation at the date of its organization, May 10, 1927, and continued to own it through 1927 and 1928. Held, the corporations were not entitled to file consolidated returns for…

1Opinion of the Court

THE PEERLESS PATTERN COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ILLUSTRATED FASHION FEATURES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Peerless Pattern Co. v. Commissioner

Docket Nos. 54291, 59360, 59361.

United States Board of Tax Appeals

29 B.T.A. 767; 1934 BTA LEXIS 1486;

January 16, 1934, Promulgated

1. The same individual owned all the outstanding voting stock of one corporation in the years 1926, 1927, and 1928, and over 95 percent of the outstanding voting stock of a second corporation from October 18, 1926, during the remainder of that…

2Cases cited1 opinion

  1. Peerless Pattern Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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