Pelican Ice Co. v. Commissioner

BRYAN, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals upon proceedings for redetermination of deficiencies in taxes on income and excess profits for the years 1920 and 1921 of the Pelican lee Company and the Pelican Cold-Storage & Warehouse Company. That decision, which is reported in 11 B. T. A. 75, held that the two corporations were not afliliated within the meaning of the Revenue Acts of 1918 and 1921, each of which in section 240: provides: “Por the purpose of this section two or more domestic corporations shall be deemed to be…