F. H. Peavey & Co. v. United States

WILLIAMS, Judge.

The plaintiff, a Minnesota corporation, sues to recover the sum of $29,112.87, corporation income tax, alleged to have been erroneously collected from tbe plaintiff for tbe calendar year 1922, together with interest thereon.

During the year 1922 the plaintiff owned 51 per cent, of the outstanding capital stock of the British America Elevator Company, Ltd., a corporation organized under the laws of the Dominion of Canada, which corporation in turn owned the entire 190 per cent, capital stock of the Port Arthur Elevator Company, Ltd., also a Canadian corporation.

During the year…