Dolese & Shepherd Co. v. Commissioner
United States Board of Tax Appeals
The petitioner was created under a syndicate agreement by the stockholders of a corporation for the purpose of acquiring and selling certain securities held by the corporation and liquidating the corporation's indebtedness, for which such securities were pledged. Held, that the petitioner was not an association taxable as a corporation.
1Opinion of the Court
OPINION.
Smith :
This proceeding is for the redetennination of a proposed deficiency in income tax for 1924 in the amount of $31,552.40. The petitioner alleges that the respondent has erroneously held that it was an association taxable as a corporation in 1924 and that it realized a taxable gain upon the sale of certain property in that year. The material facts have been stipulated and, for the purpose of this decision, are summarized as follows:
The Dolese & Shepherd Co. is an Illinois corporation which for many years has been engaged in the business of quarrying and selling crushed stone. Its…
2Cases cited8 opinions
- Investment Trust of Mut. Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Twin Bell Oil Syndicate v. CommissionerUnited States Board of Tax Appeals · 1932
- Adelaide Park Land v. CommissionerUnited States Board of Tax Appeals · 1932
- Monrovia Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Swanson v. CommissionerUnited States Board of Tax Appeals · 1934
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3Cited by4 opinions
- Dolese & Shepherd Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Marlborough House, Inc. v. CommissionerUnited States Board of Tax Appeals · 1939
- Mortgage Trust Certificate Pool v. CommissionerUnited States Board of Tax Appeals · 1940
- Seerley v. CommissionerUnited States Board of Tax Appeals · 1940