Gehring Publishing Co. v. Commissioner
United States Tax Court
1. Petitioners are a parent corporation and two subsidiaries. During 1933 because of financial difficulties the stockholders of the parent corporation agreed to turn the management of all three corporations over to three voting trustees, two of whom were large creditors of the parent company.
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1. Petitioners are a parent corporation and two subsidiaries. During 1933 because of financial difficulties the stockholders of the parent corporation agreed to turn the management of all three corporations over to three voting trustees, two of whom were large creditors of the parent company. On April 1, 1933, the parent company entered into a four-party agreement, the substance of which was that in consideration for an extension by the creditors of payment of liabilities the parent company would within thirty days "After the close of each calendar year" determine the net profits of the…
1Opinion of the Court
OPINION.
Black, Judge:
These proceedings involve two questions. The first question is common to all the petitioners for both of the taxable years 1936 and 1937, and is whether, in computing the surtax on undistributed profits under section 14 of the Revenue Act of 1936 as amended by section 501 of the Revenue Act of 1942, petitioners are entitled to credits such as are provided in section 26 (c) of the same act, as also amended by the said section 501, relating to restrictions on payment of dividends. The second question involves only petitioner Ahrens Publishing Co. for the taxable year 1937,…
2Cases cited3 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Helvering v. American Chicle Co.Supreme Court of the United States · 1934
- Helvering v. Ohio Leather Co.Supreme Court of the United States · 1942
3Cited by27 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Millar v. CommissionerUnited States Tax Court · 1977
- Denman Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1950
- Inter-City Television Film Corp. v. CommissionerUnited States Tax Court · 1964
- Fidelity-Philadelphia Trust Co. v. CommissionerUnited States Tax Court · 1954
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