Columbia Pacific Shipping Co. v. Commissioner

*969OPINION.

Aeundell :

The errors assigned by the petitioner are (a) that the Commissioner erred by holding that it and the China Pacific Co., the owner of all of the capital stock of the petitioner, properly filed separate returns of income for 1928, and (b) that the Commissioner erred by including as taxable income of the petitioner the amount of $165,688.89, claimed to represent a profit realized by petitioner in connection with the declaration and discharge- of a dividend declared. May 15, 1928, because of the difference between the cost ($1,861.11) and the declared fair market value.…