DocketNumber: 8830
Citation Numbers: 149 F.2d 968
Judges: Dobie, Goodrich, and McLaughlin, Circuit Judges
Filed Date: 5/31/1945
Status: Precedential
Modified Date: 8/22/2023
Circuit Court of Appeals, Third Circuit.
J. Marvin Haynes, of Washington, D. C. (James O. Wynn, W. C. Magathan and W. T. Sherwood, Jr., all of Washington, D. C., on the brief), for petitioner.
Ernest R. Mortenson, of Washington, D. C., (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Robert N. Anderson, and Harry Baum, Sp. Assts. to Atty. Gen., on the brief), for respondent.
Before DOBIE, GOODRICH, and McLAUGHLIN, Circuit Judges.
PER CURIAM.
This is an appeal from a decision of the Tax Court of the United States, which disallowed a deduction claimed by the petitioner, Crown Cork International Corporation. Petitioner based its claim for a deduction on an alleged capital loss sustained in 1939, when petitioner sold 12,000 shares of the capital stock of Societe du Bouchon Couronne, S. A., to Foreign Manufacturers Finance Corporation, a subsidiary wholly owned by petitioner.
The Tax Court based its refusal to allow the claimed deduction upon the ground that, under all the circumstances here attendant, the alleged sale by the parent corporation to the subsidiary corporation lacked economic reality. We agree with the decision of the Tax Court and we deem it unnecessary to add to the opinion filed in that Court, 4 T.C. 19.
We accordingly affirmed the decision of the Tax Court of the United States.
National Lead Company v. Commissioner of Internal Revenue , 336 F.2d 134 ( 1964 )
Investers Diversified Services, Inc. v. Commissioner of ... , 325 F.2d 341 ( 1963 )
Transport Mfg. & Equipment Co. v. Commissioner , 27 T.C.M. 924 ( 1968 )
Sugarman v. Commissioner , 21 T.C.M. 1018 ( 1962 )
Johnson v. Commissioner , 24 T.C. 107 ( 1955 )
National Lead Co. v. Commissioner , 40 T.C. 282 ( 1963 )
Lomas Santa Fe, Inc. v. Commissioner , 74 T.C. 662 ( 1980 )
Derr v. Commissioner , 77 T.C. 708 ( 1981 )
Decon Corp. v. Commissioner , 65 T.C. 829 ( 1976 )
Pechiney Ugine Kuhlmann Corp. v. Commissioner , 51 T.C.M. 1210 ( 1986 )