Duckworth Co. v. Commissioner
United States Board of Tax Appeals
A domestic corporation, whose principal stockholder owned the controlling interest in a British partnership, permitted the partnership to hold and use the greater part of its capital and surplus and was allowed interest on outstanding balances at the close of the year.
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A domestic corporation, whose principal stockholder owned the controlling interest in a British partnership, permitted the partnership to hold and use the greater part of its capital and surplus and was allowed interest on outstanding balances at the close of the year. Great Britain, charging the partnership with income tax on the income of the corporation as well as the partnership, assessed a tax against the partnership in respect of the interest allowed to the corporation, which was paid by the partnership and charged to the corporation. Held, in the absence of proof that this tax was,…
1Opinion of the Court
OPINION.
SteRNhagen :
The respondent determined a deficiency of $6,837.29 in petitioner’s income tax for the fiscal year ended June 30, 1925. This resulted from the reduction of petitioner’s statutory net loss for the prior year. This, in turn, resulted from respondent’s determination as to two items. Both items were assailed in the petition, but the attack on the first item was abandoned at the hearing and in respect of this issue the respondent’s determination is sustained.
The respondent by amended answer affirmatively corrects an error in his computation, the facts of which are admitted by…
2Cited by4 opinions
- Gleason Works v. CommissionerUnited States Tax Court · 1972
- Peterson v. CommissionerUnited States Board of Tax Appeals · 1934
- Duckworth Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Gleason Works v. CommissionerUnited States Tax Court · 1972