Beneficial Loan Soc. v. Commissioner of Internal Revenue

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The case is submitted upon an agreed stipulation of facts. The petitioner, a Delaware corporation, was organized in 1913 and was thereafter engaged in the business of making industrial loans. During the years 1923, 1924, and 1925,, it conducted its business in various localities through subsidiary companies, some of which were incorporated and others unincorporated. The affiliated group, consisting of the petitioner, its branches, and subsidiaries, received dividends during the fiscal year ending…