Legal Opinion

Braden Steel Corp. v. Commissioner

United States Board of Tax Appeals

Decided September 14, 1934No. Docket No. 54902Published

As of January 1, 1926, the A company, a trust taxable as a corporation, caused the B company, a corporation, to be organized and immediately thereafter acquired all of the capital stock of the latter, which it has since continued to own. For 1926 and 1927 the two companies filed separate income tax returns.

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As of January 1, 1926, the A company, a trust taxable as a corporation, caused the B company, a corporation, to be organized and immediately thereafter acquired all of the capital stock of the latter, which it has since continued to own. For 1926 and 1927 the two companies filed separate income tax returns. As of January 1, 1928, the A company caused the petitioner herein to be organized and acquired all of its capital stock, which has continuously since been owned by the company. Without obtaining permission from the Commissioner, the A company, as parent, filed a consolidated return for…

1Opinion of the Court

BRADEN STEEL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Braden Steel Corp. v. Commissioner

Docket No. 54902.

United States Board of Tax Appeals

31 B.T.A. 161; 1934 BTA LEXIS 1146;

September 14, 1934, Promulgated

As of January 1, 1926, the A company, a trust taxable as a corporation, caused the B company, a corporation, to be organized and immediately thereafter acquired all of the capital stock of the latter, which it has since continued to own. For 1926 and 1927 the two companies filed separate income tax returns. As of January 1, 1928, the A company caused the…

2Cases cited4 opinions

  1. Smith Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Imperial Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Huntington Beach, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Braden Steel Corp. v. CommissionerUnited States Board of Tax Appeals · 1934

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