Northwestern Steel & Supply Co. v. Commissioner
United States Tax Court
Hansen Building, Inc., held 80 percent or more of the stock of Northwestern. Archerd, an employee of Northwestern, owned a small percentage of Northwestern's stock and in addition held an option to acquire sufficient unissued stock from Northwestern so as to increase his percentage of ownership to 25 percent.
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Hansen Building, Inc., held 80 percent or more of the stock of Northwestern. Archerd, an employee of Northwestern, owned a small percentage of Northwestern's stock and in addition held an option to acquire sufficient unissued stock from Northwestern so as to increase his percentage of ownership to 25 percent. Held: Hansen Building, Inc., owned at least 80 percent of Northwestern's stock and therefore Hansen Building, Inc., and Northwestern are component members of a parent-subsidiary controlled group as defined in sec. 1563(a)(1), thereby entitled to only one surtax exemption. The…
1Opinion of the Court
Sterrett, Judge:
Tbe Commissioner determined deficiencies in petitioners’ Federal income taxes as follows:
Docket No. Year Amount (3/31/66 5003-71 -<3/31/67 13/31/68 5001-71 (2¡28167 (2/29/68 $3,250.00 3,414.22 3,526.89 3,944.71 3,474.82 Petitioner Northwestern Steel & Supply Co., Inc.. Hansen Building Specialties, Inc..
Due to concessions, tbe sole issue remaining for adjudication is whether Northwestern Steel & Supply Co., Inc., and Hansen Building-Specialties, Inc., were members of a parent-subsidiary controlled group within the meaning of section 1563(a)(1), I.R..C. 1954,1 and thus limited…
2Cases cited4 opinions
- J. Milton Sorem and Wanda M. Sorem v. Commissioner of Internal Revenue, R. W. Boogaart and Margaret Boogaart v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1964
- Sorem v. CommissionerUnited States Tax Court · 1963
- Gerald M. Friend v. United StatesCourt of Appeals for the First Circuit · 1965
- Bloch v. United StatesDistrict Court, S.D. Texas · 1966
3Cited by8 opinions
- Henry T. Patterson Trust, by Its Trustee, the Reeves Banking & Trust Company v. United StatesCourt of Appeals for the Sixth Circuit · 1984
- Morris v. CommissionerUnited States Tax Court · 1978
- Complete Finance Corp. v. CommissionerUnited States Tax Court · 1983
- Complete Finance Corp. v. CommissionerUnited States Tax Court · 1983
- Morris v. CommissionerUnited States Tax Court · 1978
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