Henry C. Beck Company v. Commissioner of Internal Revenue

The Commissioner of Internal Revenue appeals from a decision of the Tax Court, which held that a distribution of funds by a corporation wholly-owned by appellee, Henry C. Beck Company (Beck) and its joint venturer, Utah Construction and Mining Co. (Utah), was a dividend paid from the earnings and profits of the subsidiary within the meaning of Sections 301 and 316, I.R.C. 1954, thereby qualifying as a dividend received by a corporation under Section 243, I.R.C.1954, and did not represent income received from a collapsible corporation under Section 341, I.R.C.1954.

The subsidiary, Ridgeview…