Johnson Bronze Co. v. Commissioner
United States Tax Court
Petitioner corporation formed a subsidiary for the purpose of expanding its business in foreign countries beyond sales activities and subsequently turned the majority of its foreign sales accounts over to the subsidiary. Held, the subsidiary was a viable entity. Held further, the transactions attributed to the subsidiary were correctly attributed.
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Petitioner corporation formed a subsidiary for the purpose of expanding its business in foreign countries beyond sales activities and subsequently turned the majority of its foreign sales accounts over to the subsidiary. Held, the subsidiary was a viable entity. Held further, the transactions attributed to the subsidiary were correctly attributed. Held further, respondent's allocation to petitioner of 100 percent of the income of the subsidiary was a clear abuse of discretion. Correct allocation determined.
1Opinion of the Court
Johnson Bronze Company v. Commissioner.
Johnson Bronze Co. v. Commissioner
Docket No. 4306-62.
United States Tax Court
T.C. Memo 1965-281; 1965 Tax Ct. Memo LEXIS 47; 24 T.C.M. (CCH) 1542; T.C.M. (RIA) 65281;
October 26, 1965
Petitioner corporation formed a subsidiary for the purpose of expanding its business in foreign countries beyond sales activities and subsequently turned the majority of its foreign sales accounts over to the subsidiary. Held, the subsidiary was a viable entity. Held further, the transactions attributed to the subsidiary were correctly attributed. Held further, respondent's…
2Cases cited12 opinions
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- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
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