Pioneer Parachute Co. v. Commissioner of Internal Rev.

SWAN, Circuit Judge.

The sole question presented by this petition is whether Pioneer Parachute Company, Inc., a Connecticut corporation, and Cheney Brothers, also a Connecticut corporation, were an “affiliated group,” as defined in § 730(d) of the Internal Revenue Code, as amended, 26 U.S.C.A. Int.Rev. Code, § 730(d), from March 30 to December 31, 1941, and privileged as such to file a consolidated excess profits tax return for that period. As applied to the facts of this case section 730(d) requires that Cheney Brothers (the parent corporation) own “at least 95 per centum of each class of the…