Anderson-Clayton Sec. Corp. v. Commissioner
United States Board of Tax Appeals
1. Anderson-Clayton Industries, Inc., an affiliate of petitioner, owned 100 percent of the preferred stock and 64 percent of the shares of common stock of each of six other companies. The preferred stock of the six companies had a voting power of 50 votes per share and a par value of $100 per share. The common stock of the six companies had a voting power of one vote per share and a par value of $2 per share.
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1. Anderson-Clayton Industries, Inc., an affiliate of petitioner, owned 100 percent of the preferred stock and 64 percent of the shares of common stock of each of six other companies. The preferred stock of the six companies had a voting power of 50 votes per share and a par value of $100 per share. The common stock of the six companies had a voting power of one vote per share and a par value of $2 per share. Held, the six companies were affiliated, within the meaning of section 141(d) of the Revenue Act of 1928; as Anderson-Clayton Industries, Inc., owned more than 95 percent of each of…
1Opinion of the Court
OPINION.
Miller :
The Commissioner determined a deficiency in income tax of the petitioner and afiiliated companies for the fiscal year ended July 81,1931, in the amount of $17,837.44.
The petitioner contends that the respondent erred (1) in holding that the Abilene Cotton Oil Co., the Lockney Cotton Oil Co., Munday Cotton Oil Co., Plainview Cotton Oil Co., Slaten Cotton Oil Co., and Winters Cotton Oil Co. were not affiliated during the fiscal year ended July 31, 1931, with the affiliated group of which the petitioner is the parent corporation; (2) in failing to allow as a credit the amount of…
2Cases cited14 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- United States v. AndersonSupreme Court of the United States · 1926
- Gould v. GouldSupreme Court of the United States · 1917
- Brown v. HelveringSupreme Court of the United States · 1934
- United States v. FieldSupreme Court of the United States · 1921
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