Edward Sec. Corp. v. Commissioner
United States Board of Tax Appeals
A corporation is an entity distinct from its stockholders, and only under exceptional or unusual circumstances can the corporate entity be disregarded. The sale of stock at the market price by a corporation to its stockholder, owning all but two of its shares and controlling those, under all the other facts and circumstances, was a bona fide sale.
1Opinion of the Court
EDWARD SECURITIES CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Edward Sec. Corp. v. Commissioner
Docket No. 71208.
United States Board of Tax Appeals
30 B.T.A. 918; 1934 BTA LEXIS 1248;
June 14, 1934, Promulgated
A corporation is an entity distinct from its stockholders, and only under exceptional or unusual circumstances can the corporate entity be disregarded. The sale of stock at the market price by a corporation to its stockholder, owning all but two of its shares and controlling those, under all the other facts and circumstances, was a bona fide sale.
Harry N.…
2Cases cited32 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Eisner v. MacOmberSupreme Court of the United States · 1920
- United States Ex Rel. Attorney General of the United States v. Delaware & Hudson Co.Supreme Court of the United States · 1909
- United States v. PhellisSupreme Court of the United States · 1921
- Burnet v. ClarkSupreme Court of the United States · 1932
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