Seminole Flavor Co. v. Commissioner
United States Tax Court
The stockholders of petitioner, which was engaged in the manufacture and sale of concentrates to bottlers for processing and sale of soft drinks to the public, in order to effectively overcome merchandising difficulties, provide better cooperation with the bottlers, create an increased demand by the public for the bottlers' products and thereby increase sales of petitioner's products, created a partnership which thereafter carried on the business for which it was organized…
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The stockholders of petitioner, which was engaged in the manufacture and sale of concentrates to bottlers for processing and sale of soft drinks to the public, in order to effectively overcome merchandising difficulties, provide better cooperation with the bottlers, create an increased demand by the public for the bottlers' products and thereby increase sales of petitioner's products, created a partnership which thereafter carried on the business for which it was organized under a contract with the petitioner. Their interests in the partnership were the same as their stock interests in…
1Opinion of the Court
OPINION.
Arnold, Judge:
The issue herein involves an interpretation, construction, and application of section 45 of the Internal Revenue Code, set forth in the margin.1 Section 19.45-1 of Regulations 103 defines the terms used in section 45, its scope and purpose, and the application thereof. Section 45 is not a new provision in the code. Much of the language found therein can be traced back through prior acts to section 240 (d) of the Revenue Act of 1921. It first appeared in its present form as section 45 in the Revenue Act of 1928. Despite its long history as an integral part of the revenue…
2Cases cited7 opinions
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