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Commissioner of Internal Revenue v. Bell

September 20, 1933

COMMISSIONER OF INTERNAL REVENUE
v.
SAMUEL BELL & SONS (THREE CASES); SAME V. MOORE BREAD CO.



Petitions for Review from the United States Board of Tax Appeals.

Author: Davis

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

DAVIS, Circuit Judge.

The Commissioner of Internal Revenue contends that the Board of Tax Appeals erred in determining that the respondent Samuel Bell & Sons was affiliated with six other corporations during the years, 1924, 1926, and 1927, within the meaning of section 240 (c) of the Revenue Acts of 1924 and 1926 (26 USCA ยง 993 and note) which provides in part: "For the purpose of this section two or more domestic corporations shall be deemed to be affiliated * * * if at least 95 per centum of the voting stock of two or more corporations is owned by the same interests."

During the taxable years involved Samuel Bell & Sons and six other corporations were engaged in related businesses under a common management. The percentage of the stock in the several corporations was held as follows:

Stockholders Samuel Quaker Acheson Moore Commer- Woodbury

Bell & City Bread Bread cial Ga- Realty

Sons Flour Company Company rage Co. Company

Mills

Per cent. Per cent. Per cent. Per cent. Per cent. Per cent.

of stock stock stock stock stock stock

owned owned owned owned owned owned

Samuel Bell jr. 40.00 42.27 45.00 45.00 ...


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