Grenada Industries, Inc. v. Commissioner
United States Tax Court
Two corporations, Industries and National, and two partnerships, Hosiery and Abar, were owned or controlled directly or indirectly by the same interests. On respondent's allocation of the income of the two partnerships to the two corporations, held, (1) allocation of Abar's income to the two corporations disapproved; (2) allocation of Hosiery's income to Industries approved; (3) allocation of Hosiery's income to National disapproved.
1Opinion of the Court
OPINION.
Baum, Judge:
1. At the outset, we dispose of respondent’s contention that the asserted deficiencies are supported by section 22 (a) of the Internal Revenue Code. Throughout the argument based upon section 22 (a) there is implicit the suggestion that the entities of Hosiery and Abar should be disregarded and that their income be attributed to Industries and National. We cannot accept that position.
Hosiery and Abar were functioning entities. Each in fact rendered valuable services. True, all four organizations were actually controlled by the same persons, and neither Hosiery nor Abar had…
2Cases cited10 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Lucas v. EarlSupreme Court of the United States · 1930
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
5 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- B. Forman Co. v. CommissionerCourt of Appeals for the Second Circuit · 1972
- Raymond Pearson Motor Company and Raymond Pearson, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Liberty Loan Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1974
- B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal Revenue, B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972
- Schering Corp. v. CommissionerUnited States Tax Court · 1978
7 more not listed; retrieve them via the Exa API.