Peerless Pattern Co. v. Commissioner
United States Board of Tax Appeals
1. The same individual owned all the outstanding voting stock of one corporation in the years 1926, 1927, and 1928, and over 95 percent of the outstanding voting stock of a second corporation from October 18, 1926, during the remainder of that year and throughout 1927 and 1928. The two corporations filed returns on a separate basis for 1926. The aforesaid same individual became the owner of all the stock of a third corporation at the date of its organization, May 10, 1927,…
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1. The same individual owned all the outstanding voting stock of one corporation in the years 1926, 1927, and 1928, and over 95 percent of the outstanding voting stock of a second corporation from October 18, 1926, during the remainder of that year and throughout 1927 and 1928. The two corporations filed returns on a separate basis for 1926. The aforesaid same individual became the owner of all the stock of a third corporation at the date of its organization, May 10, 1927, and continued to own it through 1927 and 1928. Held, the corporations were not entitled to file consolidated returns for…
1Opinion of the Court
*770OPINION.
Seawell:
The record shows that the same individual, John H. Wright, owned all the outstanding common stock of To-day’s Housewife, Inc., during the years 1926,1927, and 1928, and also owned, from October 18, 1926, during the remainder of that year and throughout 1927 and 1928, over 95 percent of the outstanding common stock of the Peerless Pattern Co. It is further shown that at the time of its incorporation, May 10, 1927, he acquired and continued to own through 1927 and 1928 all the outstanding capital stock of the Illustrated Fashion Features, Inc.
It is seen, therefore, that all…
2Cases cited10 opinions
- Parker v. CommissionerUnited States Board of Tax Appeals · 1928
- Albert Leon & Son, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933
- Barron v. CommissionerUnited States Board of Tax Appeals · 1929
- Imperial Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Brownsville Ice & Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1929
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3Cited by3 opinions
- Smith Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Huntington Beach, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
- Peerless Pattern Co. v. CommissionerUnited States Board of Tax Appeals · 1934