Tide Water Oil Co. v. Commissioner
United States Board of Tax Appeals
1. Where a corporation owns 85 percent of the stock of another corporation, and the remainder is owned by individuals some of whom are also owners of about 3 percent of the stock of the former, and there is no enforceable control of the remainder, the two corporations are not affiliated, within section 240(b)(1), Revenue Act of 1918, since ownership of 85 percent is not ownership of substantially all of the stock. 2. Where 2,000 persons own in the aggregate 97 percent of the…
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1. Where a corporation owns 85 percent of the stock of another corporation, and the remainder is owned by individuals some of whom are also owners of about 3 percent of the stock of the former, and there is no enforceable control of the remainder, the two corporations are not affiliated, within section 240(b)(1), Revenue Act of 1918, since ownership of 85 percent is not ownership of substantially all of the stock. 2. Where 2,000 persons own in the aggregate 97 percent of the stock of one corporation and none of the stock of another corporation, and the former corporation owns 85 percent of…
1Opinion of the Court
TIDE WATER OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Tide Water Oil Co. v. Commissioner
Docket No. 39936.
United States Board of Tax Appeals
29 B.T.A. 1208; 1934 BTA LEXIS 1401;
February 27, 1934, Promulgated
1. Where a corporation owns 85 percent of the stock of another corporation, and the remainder is owned by individuals some of whom are also owners of about 3 percent of the stock of the former, and there is no enforceable control of the remainder, the two corporations are not affiliated, within section 240(b)(1), Revenue Act of 1918, since ownership of 85…
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