Sterno Sales Corp. v. United States

Sterno Sales Corporation (the taxpayer) and a sister corporation, Sterno, Inc., were for many years, including the taxable year 1951, wholly-owned subsidiaries of Sterno Corporation.1 All three companies were concerned with “■Sterno” canned heat and related products. Sterno, Inc. marketed and distributed the goods. Sterno Sales was the exclusive sales representative for Sterno, Inc. Prior to 1951, the latter paid Sterno Sales, for this work, an annual commission precisely equal to Sterno Sales’ expenses during the calendar year. In December 1951, the two corporations *508('Sterno, Inc. and Sterno…