Clay v. Commissioner
United States Board of Tax Appeals
PERSONAL HOLDING COMPANY INCOME REPORTED BY STOCKHOLDER. - Where a sole stockholder of a personal holding company elects to be taxed under section 351(d) of the Revenue Act of 1934, the Commissioner may increase to the correct amount the amount she reports as her entire share of the adjusted net income of the corporation.
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined a deficiency of $87.78 in the petitioner’s income tax for 1934. The issue for decision is whether the Commissioner has the right to include in the income of the petitioner undistributed income of a personal holding company in excess of the amount reported by the petitioner on her return where she elected to be taxed under section 351 (d) of the Revenue Act of 1934. The facts have been stipulated and are found in accordance with the stipulation.
The petitioner owned all of the stock of the C. E. J. Holding Co., a personal holding company within the…
2Cases cited1 opinion
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
3Cited by2 opinions
- Bleser v. CommissionerUnited States Board of Tax Appeals · 1940
- Clay v. CommissionerUnited States Board of Tax Appeals · 1939