Founders General Corp. v. Commissioner of Internal Revenue

CHASE, Circuit Judge.

During all the time material to the issues presented, the petitioner was the wholly owned subsidiary of the American Founders Corporation, the successor to American Founders Trust. Both were Maryland corporations. Petitioner was organized primarily as a marketing subsidiary for the securities of its parent, and affiliated and associated corporations.

American Founders Corporation filed a consolidated income tax return for the taxable period here involved in the office of the collector of internal revenue for the Second District of New York, which included the petitioner,…