Legal Opinion

Union Tel. Co. v. Commissioner

United States Board of Tax Appeals

Decided May 29, 1941No. Docket Nos. 99820, 102494Published

Petitioner's common stock was owned by X corporation. The latter's common stock was owned by Y corporation, which also, together with an individual and Z corporation, owned all of X's preferred stock. Y, Z, and the Individual, as owners of X's pre ferred stock, entered into a contract which provided, among other things, that no dividend should be declared by X or any of its subsidiaries until their indebtedness should be paid.

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Petitioner's common stock was owned by X corporation. The latter's common stock was owned by Y corporation, which also, together with an individual and Z corporation, owned all of X's preferred stock. Y, Z, and the Individual, as owners of X's pre ferred stock, entered into a contract which provided, among other things, that no dividend should be declared by X or any of its subsidiaries until their indebtedness should be paid. By custom Y acted in contractual matters for petitioner, which acquiesced in such action. Held, that the contract was not executed by petitioner within the meaning of…

1Opinion of the Court

UNION TELEPHONE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Union Tel. Co. v. Commissioner

Docket Nos. 99820, 102494.

United States Board of Tax Appeals

44 B.T.A. 607; 1941 BTA LEXIS 1303;

May 29, 1941, Promulgated

Petitioner's common stock was owned by X corporation. The latter's common stock was owned by Y corporation, which also, together with an individual and Z corporation, owned all of X's preferred stock. Y, Z, and the Individual, as owners of X's pre ferred stock, entered into a contract which provided, among other things, that no dividend should be declared by X…

2Cases cited1 opinion

  1. Union Tel. Co. v. CommissionerUnited States Board of Tax Appeals · 1941

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