Braden Steel Corp. v. Commissioner
United States Board of Tax Appeals
As of January 1, 1926, the A company, a trust taxable as a corporation, caused the B company, a corporation, to be organized and immediately thereafter acquired all of the capital stock of the latter, which it has since continued to own. For 1926 and 1927 the two companies filed separate income tax returns.
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As of January 1, 1926, the A company, a trust taxable as a corporation, caused the B company, a corporation, to be organized and immediately thereafter acquired all of the capital stock of the latter, which it has since continued to own. For 1926 and 1927 the two companies filed separate income tax returns. As of January 1, 1928, the A company caused the petitioner herein to be organized and acquired all of its capital stock, which has continuously since been owned by the company. Without obtaining permission from the Commissioner, the A company, as parent, filed a consolidated return for…
1Opinion of the Court
opinion. '
Trammell:
This proceeding is for the redetermination of a deficiency in income tax of $2,632.71 for 1928. The only matter in controversy is the action of the respondent in determining the tax liability of the petitioner on the basis of a separate return instead of on the basis of a consolidated return with two other companies.
The proceeding was submitted on an agreed statement of facts, pertinent portions of which are as follows:
The Braden Company, owning 100% of the stock of the petitioner, is an express Trust, organized in 1923 under the Laws of Oklahoma, with 20,000 shares of a…
2Cases cited3 opinions
- Smith Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Imperial Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Huntington Beach, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by1 opinion
- Braden Steel Corp. v. CommissionerUnited States Board of Tax Appeals · 1934