Legal Opinion

John Scowcroft & Sons Co. v. Commissioner

United States Board of Tax Appeals

Decided December 18, 1929No. Docket No. 29583Published

Where two corporations are affiliated the consolidated net income is to be computed as for one corporation and the sale by one of such corporations of some of its stockholdings in the other, affiliation continuing, should be treated, for the purpose of the income tax, as a sale by the affiliated group of its capital stock and as a capital transaction, giving rise to neither a taxable gain nor a deductible loss.

1Opinion of the Court

JOHN SCOWCROFT & SONS CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

John Scowcroft & Sons Co. v. Commissioner

Docket No. 29583.

United States Board of Tax Appeals

18 B.T.A. 532; 1929 BTA LEXIS 2021;

December 18, 1929, Promulgated

Where two corporations are affiliated the consolidated net income is to be computed as for one corporation and the sale by one of such corporations of some of its stockholdings in the other, affiliation continuing, should be treated, for the purpose of the income tax, as a sale by the affiliated group of its capital stock and as a capital transaction,…

2Cases cited1 opinion

  1. John Scowcroft & Sons Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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