Pennsylvania-Dixie Cement Corp. v. United States

WHALEY, Judge.

In 1917, the Kingsport Power Corporation, a Virginia corporation, distributed all of its assets among its stockholders and dissolved. During its existence, and at the time of its dissolution, all of its outstanding stoek was owned and held by the Clinchfleld Portland Cement Corporation. Thereafter the Commissioner of Internal Revenue made on February 19, 1924, a deficiency assessment against it for income taxes for the year 1917 in the amount of $3,076.48 and also a 5 per cent, penalty amounting to $153.82. The notice of deficiency assessment and demand for payment were…