Legal Opinion

Clay v. Commissioner

United States Board of Tax Appeals

Decided September 15, 1939No. Docket No. 93356Published

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

ZAIDA CLAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Clay v. Commissioner

Docket No. 93356.

United States Board of Tax Appeals

40 B.T.A. 562; 1939 BTA LEXIS 832;

September 15, 1939, Promulgated

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.

M. E. Kilpatrick, Esq., for the petitioner.

L. W. Creason, Esq., for…

2Cases cited6 opinions

  1. Pacific National Co. v. WelchSupreme Court of the United States · 1938
  2. Collateral Mortg. & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
  3. Curtis v. CommissionerUnited States Board of Tax Appeals · 1937
  4. Automobile Loans, Inc. v. CommissionerUnited States Board of Tax Appeals · 1937
  5. Clay v. CommissionerUnited States Board of Tax Appeals · 1939

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