Legal Opinion

Security Co. v. Commissioner

United States Board of Tax Appeals

Decided October 24, 1935No. Docket No. 57090Published

Profit which was derived by a member of an affiliated group from the sale of stock of another member of the group, where the stock in question was acquired in the form of stock dividends and the sale of the same did not break the affiliation, is liable to income tax.

1Opinion of the Court

SECURITY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Security Co. v. Commissioner

Docket No. 57090.

United States Board of Tax Appeals

33 B.T.A. 266; 1935 BTA LEXIS 774;

October 24, 1935, Promulgated

Profit which was derived by a member of an affiliated group from the sale of stock of another member of the group, where the stock in question was acquired in the form of stock dividends and the sale of the same did not break the affiliation, is liable to income tax.

Claude I. Parker, Esq., and John B. Milliken, Esq., for the petitioner.

Ralph E. Smith, Esq., for the respondent.

S…

2Cases cited7 opinions

  1. Farmers Deposit Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1926
  2. H. S. Crocker Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  3. James McCutcheon & Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. John Scowcroft & Sons Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  5. Ohio Central Telephone Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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