Bass v. Commissioner
United States Tax Court
In 1960, petitioner organized a Swiss corporation, and transferred to it undivided working interests in oil-producing properties. Thereafter, the corporation signed working agreements, collected royalties, made investments, and carried out other business activities. Held, the corporation is a separate entity for Federal tax purposes and its undistributed income is not properly taxable to petitioner.
1Opinion of the Court
Feati-ierston, Judge:
Respondent determined a deficiency in petitioners’ joint Federal income tax for 1963 in the amount of $2,829.54. The sole issue presented for decision is whether petitioners’ wholly owned foreign corporation is to be disregarded for tax purposes.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulations and exhibits thereto are incorporated herein by this reference.
The petitioners are husband and wife, citizens of the United States, who reside in Fort Worth, Tex., which was their place of residence at the time of filing the petition herein.…
2Cases cited16 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
- National Investors Corporation v. HoeyCourt of Appeals for the Second Circuit · 1944
11 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Northern Indiana Public Service Company v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1997
- Carnation Co. v. CommissionerUnited States Tax Court · 1978
- Hospital Corp. of America v. CommissionerUnited States Tax Court · 1983
- T. M. Britt and Jane Britt v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1970
30 more not listed; retrieve them via the Exa API.