Legal Opinion

Frelbro Corp. v. Commissioner

United States Tax Court

Decided August 18, 1961No. Docket No. 65552Published

Petitioner, an accrual basis taxpayer, prior to July of the calendar year in issue (1952), owned all the outstanding stock of Brown-Longyear Motors. It also derived income from rental of real estate and from other investments. Transactions between the two corporations (including declared but unpaid dividends) had been recorded in a system of intercompany accounts on the books of both corporations.

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Petitioner, an accrual basis taxpayer, prior to July of the calendar year in issue (1952), owned all the outstanding stock of Brown-Longyear Motors. It also derived income from rental of real estate and from other investments. Transactions between the two corporations (including declared but unpaid dividends) had been recorded in a system of intercompany accounts on the books of both corporations. The items in these accounts were discharged when and as Brown-Longyear felt it was in a cash position which enabled it to do so, there being no policy to clear the account periodically. In July…

1Opinion of the Court

Frelbro Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Frelbro Corp. v. Commissioner

Docket No. 65552

United States Tax Court

36 T.C. 864; 1961 U.S. Tax Ct. LEXIS 95;

August 18, 1961, Filed

Decision will be entered under Rule 50.

Petitioner, an accrual basis taxpayer, prior to July of the calendar year in issue (1952), owned all the outstanding stock of Brown-Longyear Motors. It also derived income from rental of real estate and from other investments. Transactions between the two corporations (including declared but unpaid dividends) had been recorded in a system of…

2Cases cited36 opinions

  1. Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
  2. Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
  3. Marr v. United StatesSupreme Court of the United States · 1925
  4. Commissioner of Internal Revenue v. SansomeCourt of Appeals for the Second Circuit · 1932
  5. Commissioner v. MunterSupreme Court of the United States · 1947

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