Northwestern Steel & Supply Co. v. Commissioner
United States Tax Court
Hansen Building, Inc., held 80 percent or more of the stock of Northwestern. Archerd, an employee of Northwestern, owned a small percentage of Northwestern's stock and in addition held an option to acquire sufficient unissued stock from Northwestern so as to increase his percentage of ownership to 25 percent.
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Hansen Building, Inc., held 80 percent or more of the stock of Northwestern. Archerd, an employee of Northwestern, owned a small percentage of Northwestern's stock and in addition held an option to acquire sufficient unissued stock from Northwestern so as to increase his percentage of ownership to 25 percent. Held: Hansen Building, Inc., owned at least 80 percent of Northwestern's stock and therefore Hansen Building, Inc., and Northwestern are component members of a parent-subsidiary controlled group as defined in sec. 1563(a)(1), thereby entitled to only one surtax exemption. The…
1Opinion of the Court
Northwestern Steel and Supply Co., Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Hansen Building Specialties, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Northwestern Steel & Supply Co. v. Commissioner
Docket Nos. 5003-71, 5004-71
United States Tax Court
60 T.C. 356; 1973 U.S. Tax Ct. LEXIS 111; 60 T.C. No. 42;
June 11, 1973, Filed
Decision will be entered for the respondent.
Hansen Building, Inc., held 80 percent or more of the stock of Northwestern. Archerd, an employee of Northwestern, owned a small percentage of Northwestern's stock and in addition held…
2Cases cited5 opinions
- J. Milton Sorem and Wanda M. Sorem v. Commissioner of Internal Revenue, R. W. Boogaart and Margaret Boogaart v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1964
- Sorem v. CommissionerUnited States Tax Court · 1963
- Gerald M. Friend v. United StatesCourt of Appeals for the First Circuit · 1965
- Northwestern Steel & Supply Co. v. CommissionerUnited States Tax Court · 1973
- Bloch v. United StatesDistrict Court, S.D. Texas · 1966