Munson S.S. Line v. Commissioner
United States Board of Tax Appeals
A corporation owned all of the stock of eight subsidiary corporations, and operated in foreign trade vessels, owned by the latter, under charter parties and informal arrangements. It exercised, through stock ownership and identity of officers and directors, complete dominion and control of the vessels, collecting the revenues, paying the expenses, and allocating to the subsidiaries what it regarded as a fair share of the net earnings of the vessels.
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A corporation owned all of the stock of eight subsidiary corporations, and operated in foreign trade vessels, owned by the latter, under charter parties and informal arrangements. It exercised, through stock ownership and identity of officers and directors, complete dominion and control of the vessels, collecting the revenues, paying the expenses, and allocating to the subsidiaries what it regarded as a fair share of the net earnings of the vessels. Held, that it was not the "owner" of said vessels within section 23 of the Merchant Marine Act, and therefore was not entitled to deduct, in…
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined a deficiency in income and excess profits taxes for the year 1920 in the amount of $182,-960.49. He made this determination upon the basis of a consolidated return filed by the petitioner for itself and certain subsidiary companies. This proceeding involves only the deficiency in excess profits tax in the amount of $178,980.52. The taxpayer companies filed an agreement with the Commissioner that the petitioner should be liable for all of the tax due. The question at issue before the Board is the amount of the deduction to which the petitioner is…
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- Atlantic Cleaners & Dyers, Inc. v. United StatesSupreme Court of the United States · 1932
- United States Ex Rel. Attorney General of the United States v. Delaware & Hudson Co.Supreme Court of the United States · 1909
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
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3Cited by1 opinion
- Munson S.S. Line v. CommissionerUnited States Board of Tax Appeals · 1934