James v. Commissioner
United States Board of Tax Appeals
1. Where a parent company owns all the stock of its subsidiary companies, in determining the source of profits or earnings of the parent company available for distribution to the stockholders, within the contemplation of section 201 of the Revenue Act of 1918, the earning of the subsidiaries should be considered only to the extent to which they have been distributed as dividends to the parent company. 2. Where in 1918 the parent corporation received dividends from a…
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1. Where a parent company owns all the stock of its subsidiary companies, in determining the source of profits or earnings of the parent company available for distribution to the stockholders, within the contemplation of section 201 of the Revenue Act of 1918, the earning of the subsidiaries should be considered only to the extent to which they have been distributed as dividends to the parent company. 2. Where in 1918 the parent corporation received dividends from a subsidiary corporation, a portion of which was paid from earnings and profits accumulated since February 28, 1913, and the…
1Opinion of the Court
ARTHUR CURTISS JAMES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
James v. Commissioner
Docket No. 2509.
United States Board of Tax Appeals
13 B.T.A. 764; 1928 BTA LEXIS 3192;
October 3, 1928, Promulgated
1. Where a parent company owns all the stock of its subsidiary companies, in determining the source of profits or earnings of the parent company available for distribution to the stockholders, within the contemplation of section 201 of the Revenue Act of 1918, the earning of the subsidiaries should be considered only to the extent to which they have been distributed as dividends…
2Cases cited11 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
- Lynch v. HornbySupreme Court of the United States · 1918
- Gulf Oil Corp. v. LewellynSupreme Court of the United States · 1918
- Lynch v. TurrishSupreme Court of the United States · 1918
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