Securities Allied Corp. v. Commissioner of Internal Revenue

SWAN, Circuit Judge.

The petitioner, Securities Allied Corporation, was organized under the laws of Delaware in September, 1929, for the purpose of buying and selling securities, participating in underwriting syndicates, and engaging in other investment activities. Its executive committee met daily to decide what securities to buy or sell; tile purchases and sales were made throug h brokers or through Chatham Phenix Corporation. The petitioner kept its books, and made its income tax returns, on an accrual basis. At the close of each of the taxable periods under consideration, namely, December…