Pelican Ice Co. v. Commissioner

SIBLEY, Circuit Judge.

In income tax returns for the years 1926 and 1927, the Commissioner and the Board of Tax Appeals refused to recognize affiliation between Pelican Ice Company and Pelican Cold Storage & Warehousing Company, thereby increasing the former’s tax. During these years one Behre was president of both corporations and practically controlled them. He, his wife, and five children owned all of the stock of Pelican Ice Company, while he and Pelican Ice Company owned a little less than 91 per cent, of the stock of the warehousing company, the remaining 9 per cent, being owned by…