Ohio Central Telephone Co. v. Commissioner

*98OPINION.

Lansdon:

The facts material to the proceeding have been stipulated. The only question is whether petitioner realized a profit of $168,090.86 when it sold the bonds and stock of its subsidiary corporation, the Ohio Central Telephone Corporation, in the taxable year. Petitioner contends that the result of the transaction is nontaxable, since the property sold consisted entirely of the securities of an affiliated corporation and was in effect the sale of its own bonds and stock. In support of its position it relies on our decisions in Simmons & Hammond Mfg. Co., 1 B.T.A. 803; Farmers…