Beneficial Corp. v. Commissioner
United States Tax Court
Amounts paid to petitioner in 1946 by its subsidiary corporations with which it filed a consolidated return for 1945 held to constitute taxable dividends to petitioner in 1946 to the extent that such payments exceeded the tax allocable to the subsidiaries in the consolidated return.
1Opinion of the Court
OPINION.
LeMire, Judge:
Respondent has determined a deficiency of $10,783.29 in petitioner’s income tax for 1946. The sole question in issue is whether amounts paid to petitioner in that year by its subsidiary corporations with whom it filed a consolidated return for 1945 constituted taxable dividends to the extent that they exceeded the tax liabilities properly allocable to the subsidiaries in the consolidated return. The facts are found as stipulated.
Petitioner is a Delaware corporation with its principal office located at Wilmington, Delaware. Its return for the year involved was filed with…
2Cases cited3 opinions
- Tar Products Corporation v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1942
- Commissioner of Internal Rev. v. AMERICAN L. & T. CO.Court of Appeals for the Seventh Circuit · 1946
- American Light & Traction Co. v. CommissionerUnited States Tax Court · 1944
3Cited by20 opinions
- Centerre Bank of Crane v. Director of RevenueSupreme Court of Missouri · 1988
- Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
- Dynamics Corporation of America (Formerly Claude Neon, Inc.) v. The United StatesUnited States Court of Claims · 1968
- The Denver & Rio Grande Western Railroad Company, a Corporation v. The United StatesUnited States Court of Claims · 1963
- Alliegro v. Pan American Bank of MiamiDistrict Court of Appeal of Florida · 1962
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