Allied Industrial Cartage Company v. Commissioner of Internal Revenue

In this case the Commissioner of the Internal Revenue appeals a decision of the Tax Court in favor of the taxpayer, Allied Industrial Cartage Company. Allied Cartage’s principal business during the period in question was the leasing of trucks and real estate to Allied Delivery Systems, Inc. A single individual, Alvin Wasserman, held all of the outstanding stock of both Allied Cartage and Delivery Systems. The Commissioner asserted a deficiency of $8,047.90 in Allied Cartage’s federal income tax for its tax year ending on February 28, 1974, contending that all of Allied Cartage’s income for…