Henry C. Beck Builders, Inc. v. Commissioner
United States Tax Court
A parent corporation's intercompany profit, properly eliminated from a consolidated return in 1953, held not to constitute income to the parent in 1957, when the parent sold all the subsidiary's stock to an unrelated party.
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A parent corporation's intercompany profit, properly eliminated from a consolidated return in 1953, held not to constitute income to the parent in 1957, when the parent sold all the subsidiary's stock to an unrelated party. On redemption of the subsidiary's preferred stock, the parent's basis is reduced by the subsidiary's losses sustained during taxable years prior to the redemption, but only to the extent such losses were availed of by the parent (there being no other subsidiaries here) during the taxable years prior to the redemption and could not have been availed of by the subsidiary…
1Opinion of the Court
OPINION
Train, Judge:
Respondent determined a deficiency in income tax of petitioner Salina Management Co., Inc. (docket No. 90108), in the amount of $129,673.89 for its taxable year ended June 80, 1957.
Respondent further determined that the remaining petitioners were liable, as transferees, for Salina Management Co., Inc.’s deficiency, as follows:
Henry O. Beck Builders, Inc. (docket No. 90101)_$41, 436. 00
First National Bank in Dallas and Henry C. Beck, Jr., Trustees under the will of Henry C. Beck, Deceased (docket No. 90102)_ 10, 631. 86
Utah Construction & Mining Co. (docket No. 90109)_ 52,…
Also in this document: Dissent.
2Cases cited32 opinions
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Commissioner v. BilderSupreme Court of the United States · 1962
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
27 more not listed; retrieve them via the Exa API.
3Cited by50 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
- Woods Inv. Co. v. CommissionerUnited States Tax Court · 1985
- Verito v. CommissionerUnited States Tax Court · 1965
- CSI Hydrostatic Testers v. CommissionerUnited States Tax Court · 1994
45 more not listed; retrieve them via the Exa API.