Worcester Salt Co. v. Commissioner
United States Board of Tax Appeals
The sale to an outsider at par during affiliation by one affiliated corporation of the bonds of another issued to it during affiliation in exchange for its assets of depreciated cost greater than the par value of the bonds thus received held to result in no deductible loss.
1Opinion of the Court
*527OPINION.
SteRniiagen :
Tlie Commissioner, after examining the returns of the Worcester Salt Co., the Kerr-Remington Salt Co., and Alexander Kerr Bro. & Co. for 1928, determined that for the first five months, until June 1, a separate return was proper for the Worcester Salt Co., and that a consolidated return for the whole year should include the year’s operations for the other two corporations and the last seven months of the Worcester Co. This is accepted by both parties as correct, and upon that basis respondent determined a deficiency of $8,808.58 for the earlier period and $4,988.75 for…
2Cases cited4 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Farmers Deposit Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1926
- Ohio Central Telephone Co. v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by2 opinions
- American Founders Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Worcester Salt Co. v. CommissionerUnited States Board of Tax Appeals · 1933