Crossett Western Co. v. Commissioner
United States Board of Tax Appeals
1. The petitioner and the Gales Creek Logging Company were incorporated prior to the year 1924. During that year the Gales Creek Logging Company's outstanding voting stock was held as follows: 72.701 per cent by petitioner, 21.482 per cent by 11 of petitioner's 28 stockholders, and 5.817 per cent by outsiders.
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1. The petitioner and the Gales Creek Logging Company were incorporated prior to the year 1924. During that year the Gales Creek Logging Company's outstanding voting stock was held as follows: 72.701 per cent by petitioner, 21.482 per cent by 11 of petitioner's 28 stockholders, and 5.817 per cent by outsiders. Held, the two companies were not affiliated. 2. Respondent denied a request that the accounts of the two companies be consolidated for the year 1924. Held, no error. 3. The two companies became affiliated on November 15, 1928. Held, under the Revenue Act of 1928 the periods January 1 to…
1Opinion of the Court
*261OPINION.
Marquette :
The principal question in these proceedings is whether the petitioner and the Gales Creek Logging Company were entitled to file consolidated returns for 1924 and subsequent years by reason of affiliation. Despondent determined with respect to the year 1924 that there was no showing of a disproportion in the inter-company accounts such as would warrant the consolidation of accounts under section 240 (d) of the Revenue Act of 1924. That section reads as follows: *
In any case of two or more related trades or businesses * * * owned or controlled directly or indirectly by the…
2Cases cited1 opinion
- Handy & Harman v. BurnetSupreme Court of the United States · 1931
3Cited by6 opinions
- Drawoh, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933
- Remco S. S. Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1936
- Remco Steamship Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- United States Trucking Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Crossett Western Co. v. CommissionerUnited States Board of Tax Appeals · 1932
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