American Bronze Corp. v. Commissioner
United States Tax Court
Petitioner Goldstein owned all of the stock of American Bronze and substantially all of the stock of Cleveland Brass Manufacturing Co. at the time Cleveland Brass sold its assets to Webster Valve Co., Inc., in October 1968. American Bronze was engaged in the "jobbing" business of making bronze castings; Cleveland Brass was engaged in the same "jobbing" business but also manufactured and sold its own "product line" of valves.
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Petitioner Goldstein owned all of the stock of American Bronze and substantially all of the stock of Cleveland Brass Manufacturing Co. at the time Cleveland Brass sold its assets to Webster Valve Co., Inc., in October 1968. American Bronze was engaged in the "jobbing" business of making bronze castings; Cleveland Brass was engaged in the same "jobbing" business but also manufactured and sold its own "product line" of valves. Webster Valve did not conduct a "jobbing" business after the sale and Cleveland Brass retained some of its jobbing business equipment and continued its jobbing business…
1Opinion of the Court
Drennen, Judge:
In these consolidated cases, respondent determined deficiencies in the Federal income tax of petitioner American Bronze Corp. for the calendar year 1970 and of petitioners Saul S. and Dorothy Goldstein for the calendar year 1968 as follows:
Year Deficiency Docket No. Petitioner
$38,865.47 9068-73 American Bronze Corp-I — i CO *<] O
1,074.46 9069-73 Saul S. and Dorothy Goldstein H-L CO 05 GO
An adjustment as to depreciation has been conceded by the petitioner (American Bronze) in docket No. 9068-73. The individual petitioners in docket No. 9069-73 have conceded the adjustment as to…
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