Title Guarantee Loan & Trust Co. v. Commissioner
This text of 15 B.T.A. 1220 (Title Guarantee Loan & Trust Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
[1222]*1222OPINION.
The question is whether substantially all of the stock of petitioner and the Beal Estate Mortgage Co. was owned or controlled by the same interests so as to result in such corporations being affiliated in 1922 as held by the Commissioner.
We are of the opinion, from the facts disclosed, that the Commissioner correctly held the corporations to be affiliated within the meaning of section 240 (c) (2) of the Revenue Act of 1921. Midland Refining Co., 2 B. T. A. 292; North McAlester Coal Co., 5 B. T. A. 200; H. B. Smith Machine Co., 7 B. T. A. 525; Nachman Spring-Filled Co., 12 B. T. A. 372; Century Music Publishing Co., 12 B. T. A. 647.
Judgment will be entered for the respondent.
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Cite This Page — Counsel Stack
15 B.T.A. 1220, 1929 BTA LEXIS 2706, Counsel Stack Legal Research, https://law.counselstack.com/opinion/title-guarantee-loan-trust-co-v-commissioner-bta-1929.