Henry C. Beck Co. v. Commissioner
United States Tax Court
In 1955, Management, a corporation wholly owned by petitioner and its joint venturer, Utah, distributed $ 250,000 to petitioner. The distribution was made by Management from a profit "realized" in 1954 from its two wholly owned corporations, but which it did not "recognize" for income tax purposes because of filing a consolidated return.
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In 1955, Management, a corporation wholly owned by petitioner and its joint venturer, Utah, distributed $ 250,000 to petitioner. The distribution was made by Management from a profit "realized" in 1954 from its two wholly owned corporations, but which it did not "recognize" for income tax purposes because of filing a consolidated return. Petitioner treated the distribution as an ordinary dividend, deducting 85 percent of the distribution under sec. 243, I.R.C. 1954, and reporting the remaining 15 percent as a taxable dividend. Respondent determined that the distribution was not a dividend…
1Opinion of the Court
Henry C. Beck Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Henry C. Beck Co. v. Commissioner
Docket No. 1686-66
United States Tax Court
52 T.C. 1; 1969 U.S. Tax Ct. LEXIS 160;
April 3, 1969, Filed
Decision will be entered for the petitioner.
In 1955, Management, a corporation wholly owned by petitioner and its joint venturer, Utah, distributed $ 250,000 to petitioner. The distribution was made by Management from a profit "realized" in 1954 from its two wholly owned corporations, but which it did not "recognize" for income tax purposes because of filing a consolidated return.…
Also in this document: Dissent.
2Cases cited18 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Commissioner v. GordonSupreme Court of the United States · 1968
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Commissioner of Internal Revenue v. Oscar E. Baan and Evelyn K. BaanCourt of Appeals for the Ninth Circuit · 1967
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