Woods Lumber Co. v. Commissioner
United States Board of Tax Appeals
1. Taxpayer, a Tennessee corporation, owned and operated prior to November 1932 a sawmill at Memphis, Tennessee, and another at Clarendon, Arkansas, together with timber and river logging equipment. Its ledger was divided into two sections, one containing accounts pertaining to the Arkansas properties and operations and the other pertaining to Memphis properties and operations and controlling accounts.
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1. Taxpayer, a Tennessee corporation, owned and operated prior to November 1932 a sawmill at Memphis, Tennessee, and another at Clarendon, Arkansas, together with timber and river logging equipment. Its ledger was divided into two sections, one containing accounts pertaining to the Arkansas properties and operations and the other pertaining to Memphis properties and operations and controlling accounts. In November 1932 three of taxpayer's stockholders obtained an Arkansas charter, but other than that no steps were taken to organize the corporation. Neither taxpayer nor its stockholders paid…
1Opinion of the Court
*92OPINION.
ARNOLD:
The Commissioner disallowed the Clarendon mill operating loss of $14,077.10 upon the ground that the Arkansas operations were conducted by a separate and distinct entity for income tax purposes. This determination was predicated on the assumption that the petitioner was the stockholder of the Arkansas company.
For income tax purposes corporations are generally treated as entities separate and distinct from their stockholders. Burnet v. Clark, 287 U. S. 410; Dalton v. Bowers, 287 U. S. 404; and Burnet v. Commonwealth Improvement Co., 287 U. S. 415. However, where exceptional or…
2Cases cited10 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Burnet v. ClarkSupreme Court of the United States · 1932
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
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- Blue Flame Gas Co. v. CommissionerUnited States Tax Court · 1970
- Cherrydale Cement Block Co. v. CommissionerUnited States Tax Court · 1962
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