Duckworth Co. v. Commissioner
United States Board of Tax Appeals
A domestic corporation, whose principal stockholder owned the controlling interest in a British partnership, permitted the partnership to hold and use the greater part of its capital and surplus and was allowed interest on outstanding balances at the close of the year.
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A domestic corporation, whose principal stockholder owned the controlling interest in a British partnership, permitted the partnership to hold and use the greater part of its capital and surplus and was allowed interest on outstanding balances at the close of the year. Great Britain, charging the partnership with income tax on the income of the corporation as well as the partnership, assessed a tax against the partnership in respect of the interest allowed to the corporation, which was paid by the partnership and charged to the corporation. Held, in the absence of proof that this tax was,…
1Opinion of the Court
THE DUCKWORTH COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Duckworth Co. v. Commissioner
Docket No. 41830.
United States Board of Tax Appeals
24 B.T.A. 304; 1931 BTA LEXIS 1663;
October 7, 1931, Promulgated
A domestic corporation, whose principal stockholder owned the controlling interest in a British partnership, permitted the partnership to hold and use the greater part of its capital and surplus and was allowed interest on outstanding balances at the close of the year. Great Britain, charging the partnership with income tax on the income of the corporation as well as the…
2Cases cited1 opinion
- Duckworth Co. v. CommissionerUnited States Board of Tax Appeals · 1931