Cantrell & Cochrane v. Commissioner
United States Board of Tax Appeals
1. Where the business of a "syndicate" was carried on jointly by a domestic corporation and a foreign corporation, held that the foreign corporation was engaged in trade or business within the United States and had an office or place of business therein. 2. The withholding return filed by the domestic corporation held not sufficient to start the period of the statute of limitations as to the tax liability of the foreign corporation, and held, further, that under such…
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1. Where the business of a "syndicate" was carried on jointly by a domestic corporation and a foreign corporation, held that the foreign corporation was engaged in trade or business within the United States and had an office or place of business therein. 2. The withholding return filed by the domestic corporation held not sufficient to start the period of the statute of limitations as to the tax liability of the foreign corporation, and held, further, that under such circumstances the Commissioner did not err in imposing a penalty against the foreign corporation for failure to file a return.
1Opinion of the Court
CANTRELL & COCHRANE, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Cantrell & Cochrane v. Commissioner
Docket No. 25041.
United States Board of Tax Appeals
19 B.T.A. 16; 1930 BTA LEXIS 2477;
February 26, 1930, Promulgated
1. Where the business of a "syndicate" was carried on jointly by a domestic corporation and a foreign corporation, held that the foreign corporation was engaged in trade or business within the United States and had an office or place of business therein.
2. The withholding return filed by the domestic corporation held not sufficient to start the period of the…
2Cases cited12 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Mabel Elevator Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- National Refining Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- F. A. Hall Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Cantrell & Cochrane v. CommissionerUnited States Board of Tax Appeals · 1930
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