Powers Photo Engraving Co., Inc. v. Commissioner of Internal Revenue

The Tax Court held the petitioner, Powers Photo Engraving Co., Inc., liable as a transferee under Section 311 of the Internal Revenue Code, 26 U.S.C.A. § 311, for the unpaid excess profits taxes for the year 1945 of its wholly owned subsidiary, Powers Electronic and Communication Co. The transferee liability of the petitioner arose out of a transfer in 1946 of $162,-948.24 from Electronic to the petitioner, which left the subsidiary with insufficient assets to pay the amount of its tax defici ency. The petitioner contended before the Tax Court that the transfer was a repayment of various…