Alprosa Watch Corp. v. Commissioner
United States Tax Court
The Esspi Glove Corporation, from the date of its incorporation until June 15, 1943, was engaged in the business of manufacturing and selling gloves. On the latter date all of the stock of Esspi was purchased by two new stockholders, its name was changed to the Alprosa Watch Corporation, its place of business was moved, and the nature of the business was changed to the buying and selling of jewelry.
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The Esspi Glove Corporation, from the date of its incorporation until June 15, 1943, was engaged in the business of manufacturing and selling gloves. On the latter date all of the stock of Esspi was purchased by two new stockholders, its name was changed to the Alprosa Watch Corporation, its place of business was moved, and the nature of the business was changed to the buying and selling of jewelry. Held, petitioner Alprosa Watch Corporation and the Esspi Glove Corporation constitute one and the same tax entity and that the income and expenses of the glove business for the period July 1,…
1Opinion of the Court
OPINION.
Arundell, Judge:
The petitioner herein, the Alprosa Watch Corporation, which was engaged in the business of selling jewelry, including watches, during the period June 15 to June 30, 1943, claims the right to include in its returns for the fiscal year ended June 30, 1943, the income and losses realized by the Esspi Glove Corporation during the preceding portion of that fiscal year and in a prior year. Petitioner also seeks the benefit of the excess profits credits of the latter corporation. These claims are predicated on the theory that petitioner and Esspi are one and the same taxable…
2Cases cited2 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
3Cited by11 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- J. G. Dudley Co. v. CommissionerUnited States Tax Court · 1961
- Julius Garfinckel & Co., Incorporated (Successor to Brooks Brothers, Inc., Formerly the A. Depinna Company) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- British Motor Car Distributors, Ltd. v. CommissionerUnited States Tax Court · 1958
- Virginia Metal Products, Inc. v. CommissionerUnited States Tax Court · 1960
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