Howard A. Jackson and Elizabeth D. Jackson v. Commissioner of Internal Revenue

FRANK, Circuit Judge.

The basic question here is whether certain corporations should be disregarded with the result that transactions carried out by them should be treated as if the corporations did not exist and as if the transactions had been those of the taxpayers themselves. The facts are fully stated in the opinion of the Tax Court, reported 24 T.C. No. 1, and we need but briefly summarize them here.

Taxpayers and two others, Cohn and Harris, each owned one-third of the stock of Empire Industries, Inc. (hereafter Empire). Empire owned numerous other corporations whose acquisition had been…