Columbian Rope Co. v. Commissioner
United States Tax Court
1. Held, the undistributed income of a wholly owned Panama subsidiary formed by petitioner for valid business purposes is not includable in petitioner's taxable income in the years 1959, 1960, and 1961. 2. Held, further, petitioner is entitled to deduct in full the salaries paid in 1959, 1960, and 1961 to executive officers whose duties included the supervision of the affairs of a wholly owned Philippine subsidiary, and the salaries paid to certain clerical personnel whose…
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1. Held, the undistributed income of a wholly owned Panama subsidiary formed by petitioner for valid business purposes is not includable in petitioner's taxable income in the years 1959, 1960, and 1961. 2. Held, further, petitioner is entitled to deduct in full the salaries paid in 1959, 1960, and 1961 to executive officers whose duties included the supervision of the affairs of a wholly owned Philippine subsidiary, and the salaries paid to certain clerical personnel whose duties included handling purchases of raw materials from the Philippine subsidiary. 3. Held, further, petitioner is not…
1Opinion of the Court
Mulroney, Judge:
Respondent determined deficiencies in the petitioner’s income tax as follows:
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In an amendment to the answer filed by respondent to the petitioner’s second amended petition in docket No. 83757, the respondent claimed an additional deficiency in petitioner’s income tax for 1957 to reflect the stipulated inclusion in petitioner’s taxable income for 1957 of the additional amount of $89,054.41. In his answer to the first amended petition filed by petitioner in docket No. 88062, the respondent claimed “any increased deficiency” for 1958 which might arise from the…
2Cases cited11 opinions
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- Boehm v. CommissionerSupreme Court of the United States · 1945
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3Cited by51 opinions
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