Columbia Pac. Shipping Co. v. Commissioner
United States Board of Tax Appeals
1. The petitioner, a corporation, affiliated in 1928 with several other corporations, requested permission of the Commissioner to be allowed to file separate returns for that year instead of filing, as formerly, a consolidated return. The request was granted and the corporations elected to file separate returns.
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1. The petitioner, a corporation, affiliated in 1928 with several other corporations, requested permission of the Commissioner to be allowed to file separate returns for that year instead of filing, as formerly, a consolidated return. The request was granted and the corporations elected to file separate returns. Held, that they were bound by such election and the Commissioner did not err in treating the separate returns as property filed and refusing thereafter to permit the filing of a consolidated return. 2. The petitioner declared a dividend payable partly in stock of another corporation…
1Opinion of the Court
*969OPINION.
Aeundell :
The errors assigned by the petitioner are (a) that the Commissioner erred by holding that it and the China Pacific Co., the owner of all of the capital stock of the petitioner, properly filed separate returns of income for 1928, and (b) that the Commissioner erred by including as taxable income of the petitioner the amount of $165,688.89, claimed to represent a profit realized by petitioner in connection with the declaration and discharge- of a dividend declared. May 15, 1928, because of the difference between the cost ($1,861.11) and the declared fair market value.…
2Cases cited5 opinions
- United States ex rel. Greylock Mills v. BlairCourt of Appeals for the D.C. Circuit · 1923
- Fontana Union Water Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Apartment Corp. v. CommissionerUnited States Board of Tax Appeals · 1929
- Brownsville Ice & Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Pine Ridge Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by1 opinion
- Columbia Pac. Shipping Co. v. CommissionerUnited States Board of Tax Appeals · 1934