Adams Bros. Co. v. Commissioner

opinion.

Tietjens, Judge:

The petitioner, a wholly owned subsidiary of Paxton & Gallagher Co., maintained two open accounts with its parent, one each for its grocery business and its liquor business. The parent advanced money by paying the petitioner’s purchase invoices. The petitioner deposited sales receipts to the parent’s account. Generally the petitioner owed the parent for advances in excess of sales for the grocery business, while the parent owed the petitioner for an excess of deposits over advances on the liquor business. Each corporation gave the other its note for the separate…