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COMMISSIONER v. PHIPPS

No. 83.

336 U.S. 410 (1949)

69 S.Ct. 616

93 L.Ed. 771

COMMISSIONER OF INTERNAL REVENUE v. PHIPPS.

Supreme Court of United States.

Decided March 14, 1949.

Attorney(s) appearing for the Case

Stanley M. Silverberg argued the cause for petitioner. With him on the brief were Solicitor General Perlman, Assistant Attorney General Caudle, Ellis N. Slack, Lee A. Jackson and Helen Goodner.

W. Clayton Carpenter argued the cause for respondent. With him on the brief were Montgomery Dorsey and William L. Branch.

MR. JUSTICE MURPHY delivered the opinion of the Court.

This case involves a tax-free liquidation by a parent corporation of some of its subsidiaries. At the time of the liquidation the parent had earnings and profits available for distribution, and the subsidiaries had an aggregate net deficit. The issue now before us is whether the rule of Commissioner v. Sansome, 60 F.2d 931, requires the subtraction of the subsidiaries...

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