T. T. Word Supply Co. v. Commissioner
United States Board of Tax Appeals
1. AFFILIATION. - Upon the evidence it is held that the T. T. Word Supply Co. was not the owner of the stock of the Lucey Manufacturing Corporation of Texas, and, therefore, was not entitled to make a consolidated return with that corporation and the Word Specialty Manufacturing Corporation for the year 1931. 2. LIQUIDATING DIVIDENDS. - Upon the evidence it is held that the petitioner, T. T. Word, was the owner of the stock and obligations of the liquidating corporation, and…
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1. AFFILIATION. - Upon the evidence it is held that the T. T. Word Supply Co. was not the owner of the stock of the Lucey Manufacturing Corporation of Texas, and, therefore, was not entitled to make a consolidated return with that corporation and the Word Specialty Manufacturing Corporation for the year 1931. 2. LIQUIDATING DIVIDENDS. - Upon the evidence it is held that the petitioner, T. T. Word, was the owner of the stock and obligations of the liquidating corporation, and the distribution of its assets to him in exchange for the stock and cancellation of the obligations was a distribution…
1Opinion of the Court
*973OPINION.
ARNOLD:
The Supply Co. filed a consolidated return for the year 1931, in which it deducted net losses of the Specialty Co. and the Texas corporation of $34,927.61. The respondent denied the right to make a consolidated return on the ground that the three corporations were not an “affiliated group”, as defined in section 141 of the Eeve-nue Act of 1928.1 In determining the tax liability of T. T. Word and Anna Word for the year 1934, the respondent held that T. T. Word acquired all of the assets of the Texas corporation in exchange for the surrender of all of its stock and the…
2Cases cited4 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
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- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Alameda Realty Corp. v. CommissionerUnited States Tax Court · 1964
- Herbert A. Nieman & Co. v. CommissionerUnited States Tax Court · 1959
- Howell v. CommissionerUnited States Tax Court · 1963
- Cleveland v. CommissionerUnited States Tax Court · 1963
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