T & K Mfg., Inc. v. Commissioner
United States Tax Court
In 1978 and 1979, petitioner-husband and another man owned, in equal shares, petitioner-corporation and a partnership. In 1978 and 1979, the corporation manufactured typewriter rollers under contract. One of the necessary steps in manufacturing typewriter rollers was rubber grinding. During 1978 and 1979, the corporation subcontracted the rubber grinding to the partnership, which in turn subcontracted the rubber grinding to an unrelated corporation.
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In 1978 and 1979, petitioner-husband and another man owned, in equal shares, petitioner-corporation and a partnership. In 1978 and 1979, the corporation manufactured typewriter rollers under contract. One of the necessary steps in manufacturing typewriter rollers was rubber grinding. During 1978 and 1979, the corporation subcontracted the rubber grinding to the partnership, which in turn subcontracted the rubber grinding to an unrelated corporation. Respondent determined that the partnership's profits on the rubber grinding are dividends to petitioner-corporation's shareholders, and…
1Opinion of the Court
T AND K MANUFACTURING, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; RAYMOND H. BUSHONG AND GWENDOLYN J. BUSHONG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T & K Mfg., Inc. v. Commissioner
Docket Nos. 11780-82, 11781-82.
United States Tax Court
T.C. Memo 1986-603; 1986 Tax Ct. Memo LEXIS 2; 52 T.C.M. (CCH) 1259; T.C.M. (RIA) 86603;
December 30, 1986.
In 1978 and 1979, petitioner-husband and another man owned, in equal shares, petitioner-corporation and a partnership. In 1978 and 1979, the corporation manufactured typewriter rollers under contract. One of the…
2Cases cited21 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Riss v. CommissionerUnited States Tax Court · 1971
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