James McCutcheon & Co. v. Commissioner
United States Board of Tax Appeals
1. During the taxable year a subsidiary corporation, all of whose outstanding stock was owned by the parent corporation, sold at a profit to employees of the parent corporation certain shares of stock it owned in the parent.
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1. During the taxable year a subsidiary corporation, all of whose outstanding stock was owned by the parent corporation, sold at a profit to employees of the parent corporation certain shares of stock it owned in the parent. Held that the profit on the transaction constitutes taxable income of the subsidiary and should be included in the taxable consolidated income of the group. 2. In February 1928 certain stock was sold for a stipulated price with interest, payable on or before October 21, 1932. The contract of sale provided for the vendor holding the stock as collateral, receiving any…
1Opinion of the Court
JAMES MCCUTCHEON & COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
James McCutcheon & Co. v. Commissioner
Docket No. 49167.
United States Board of Tax Appeals
30 B.T.A. 1177; 1934 BTA LEXIS 1211;
July 13, 1934, Promulgated
1. During the taxable year a subsidiary corporation, all of whose outstanding stock was owned by the parent corporation, sold at a profit to employees of the parent corporation certain shares of stock it owned in the parent. Held that the profit on the transaction constitutes taxable income of the subsidiary and should be included in the taxable consolidated…
2Cases cited1 opinion
- James McCutcheon & Co. v. CommissionerUnited States Board of Tax Appeals · 1934