Securities-Allied Corp. v. Commissioner
United States Board of Tax Appeals
1. Petitioner was engaged in the purchase and sale of stocks and securities, all of which transactions were made through a certain corporation or through brokers, and none for the account of customers.
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1. Petitioner was engaged in the purchase and sale of stocks and securities, all of which transactions were made through a certain corporation or through brokers, and none for the account of customers. Held, that petitioner was a management investment trust and not a "dealer in securities" entitled to return its income in 1930 on an inventory basis, either in respect of such securities or in respect of certain debentures purchased with intent to sell to the public but never sold. 2. To overcome Commissioner's determination that taxpayer is not entitled to use the inventory method in making…
1Opinion of the Court
SECURITIES-ALLIED CORPORATION (FORMERLY CHATHAM PHENIX ALLIED CORPORATION), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Securities-Allied Corp. v. Commissioner
Docket No. 78577.
United States Board of Tax Appeals
36 B.T.A. 168; 1937 BTA LEXIS 757;
June 18, 1937, Promulgated
1. Petitioner was engaged in the purchase and sale of stocks and securities, all of which transactions were made through a certain corporation or through brokers, and none for the account of customers. Held, that petitioner was a management investment trust and not a "dealer in securities" entitled to return its…
2Cases cited14 opinions
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Schafer v. HelveringSupreme Court of the United States · 1936
- Helvering v. FriedSupreme Court of the United States · 1936
- Adirondack Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
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