R. L. Blaffer & Co. v. Commissioner
United States Board of Tax Appeals
A mere holding or investment corporation held, upon the evidence, subject to the 50 percent tax of section 104, Revenue Act of 1932, notwithstanding the diminution in market value of its assets.
1Opinion of the Court
*855OPINION.
Sternhagen :
The principal question is whether, in the fiscal years ended September 30,1932,1933, and 1934, the petitioner was “formed or availed of for the purpose of preventing the imposition of the surtax upon its stockholders through the medium of permitting its gains and profits to accumulate instead of being divided or distributed” and thus subject to the 50 percent tax provided in section 104, Revenue Act of 1932. The Commissioner determined that it was, and the taxpayer in contesting the determination has undertaken to prove that it was not.
In its brief, petitioner says (p. 26):
2Cited by26 opinions
- Fisher v. CommissionerUnited States Tax Court · 1970
- Chicago Stock Yards Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1942
- World Pub. Co. v. United StatesDistrict Court, N.D. Oklahoma · 1947
- Bay Sound Transportation Co. v. United StatesDistrict Court, S.D. Texas · 1972
- Trico Products Corporation v. McGowanDistrict Court, W.D. New York · 1946
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