Helvering v. Credit Alliance Corp.

The Commercial Credit Company, a Delaware corporation, acquired and owned over 99% of the capital stock of the respondent, a New York corporation actively engaged in business. In 1936 the respondent’s stockholders and directors resolved to liquidate the corporation and to make distribution to its stockholders in liquidation. Part of the distribution so made in 1936 was of cash and property constituting surplus earned after Feb ruary 28, 1913, of the value of $950,734. Of this, Commercial Credit Company’s share was $947,228. Further distributions were made in 1937, and final distribution in…