BENEFICIAL CORPORATION v. COMMISSIONER

Docket No. 29715.

18 T.C. 396 (1952)

BENEFICIAL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 23, 1952.


Attorney(s) appearing for the Case

Jackson R. Collins, Esq., for the petitioner.

Charles J. Hickey, Esq., for the respondent.


OPINION.

LEMIRE, Judge:

Respondent has determined a deficiency of $10,783.29 in petitioner's income tax for 1946. The sole question in issue is whether amounts paid to petitioner in that year by its subsidiary corporations with whom it filed a consolidated return for 1945 constituted taxable dividends to the extent that they exceeded the tax liabilities properly allocable to the subsidiaries in the consolidated...

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