Marbelite Corp. of America v. Commissioner

WILBUR, Circuit Judge.

The petitioner 'made a tax return for 1929 and 1930 upon the theory that it was affiliated with a subsidiary corporation known as the Marbelite Corporation of. Illinois. The latter corporation had been organized .by the petitioner with a capital stock of 4,000 shares of the par value of $100 each. Of this stock' 2,995 shares had been issued to petitioner and five shares owned by petitioner were issued to directors as qualifying shares. On March 16, 1928, petitioner transferred 1,000 shares of its 2,995 shares to Bassler, Bippus, and Rose. The Commissioner held that the…