J. D. & A. B. SPRECKLES CO. v. COMMISSIONER
United States Board of Tax Appeals
The parent corporation of an affiliated group of corporations acquired all the stock of X corporation in the taxable year. The acquisition and ownership of the stock of X corporation was without any business purpose. Held, the X corporation was not a member of the affiliated group of corporations within the intent of section 141 of the Revenue Act of 1932.
1Opinion of the Court
*373OPINION.
HaeRon:
The principal issue for determination is whether or not the Tire Co. was a member of the affiliated group of corporations of which petitioner was the parent, within the intent of section 141 of the Revenue Act of 1932, during the last 10 months of 1933. In the consolidated return filed by petitioner and its affiliated corporations for the calendar year 1933, a deduction was taken for a net loss of $191,268.52, claimed to have been sustained by the Tire Co. during the period in question. The respondent disallowed the deduction on the ground that the Tire Co. was not a member of…
2Cases cited2 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
3Cited by17 opinions
- Hawaiian Trust Company Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- R. P. Collins & Co., Inc. v. United StatesCourt of Appeals for the First Circuit · 1962
- Hawaiian Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- The Zanesville Investment Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- Naeter Bros. Pub. Co. v. CommissionerUnited States Tax Court · 1964
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