Crosby Valve & Gage Co. v. Commissioner
United States Tax Court
Held, a wholly owned subsidiary of a tax-exempt charitable corporation is not entitled to deduct as charitable contributions transfers of its equity in certain bonds to its parent corporation.
1Opinion of the Court
BRUCE, Judge:
Respondent determined deficiencies in income tax for fiscal years ended October 31,1954,1955, and 1956 in the respective amounts of $8,465.88, $15,627.17, and $1,379.39.
The deficiencies in question resulted primarily from respondent’s disallowance of deductions claimed by petitioner for amortization of bond premiums, for interest expense and for assignments of its equity in said bonds to certain tax-exempt charitable organizations. In a stipulation filed by the parties at the trial, respondent has conceded: (1) That the deductions for bond amortization of bond premiums in the…
2Cases cited18 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
13 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Singer Co. v. United StatesUnited States Court of Claims · 1971
- Marquis v. CommissionerUnited States Tax Court · 1968
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
- C. F. Mueller Co. v. CommissionerUnited States Tax Court · 1970
17 more not listed; retrieve them via the Exa API.