Union Pac. R.R. v. Commissioner
United States Board of Tax Appeals
Petitioner, a steam railroad corporation, and two other steam railroad corporations were operated independently and not physically connected or merged. Held, the three corporations were not affiliated in 1917 under section 1331, Revenue Act of 1921.
1Opinion of the Court
*794OPINION.
Sternhagen:
The foregoing findings are as requested by both parties, except finding 4, which is as requested by petitioner and contrary to the request of respondent.
The respondent, in determining the deficiency for 1917, has treated petitioner and the Short Line and the Navigation Company as affiliated within his interpretation of the meaning of section 1331, Revenue Act of 1921. The petitioner contends that respondent’s construction of the statute is incorrect, and that, correctly interpreted, the statute requires that these corporations shall not be construed to be affiliated.
The…
2Cases cited1 opinion
- Gould v. GouldSupreme Court of the United States · 1917
3Cited by3 opinions
- American Textile Woolen Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Union P. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1935
- Union Pac. R.R. v. CommissionerUnited States Board of Tax Appeals · 1929