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STEEL IMPROVEMENT AND FORGE CO. v. COMMISSIONER

Docket No. 77738.

36 T.C. 265 (1961)

THE STEEL IMPROVEMENT AND FORGE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 15, 1961.

Attorney(s) appearing for the Case

Brooks W. Maccracken, Esq., for the petitioner.

William O. Allen, Esq., for the respondent.

OPINION.

SCOTT, Judge:

Respondent has determined a deficiency in the income tax of petitioner for the fiscal year ended September 30, 1954, in the amount of $33,368.19.

The issues remaining for our decision are: Whether the amount received by petitioner, nominally as a "dividend," from its wholly owned subsidiary was in legal effect a dividend, or a part of the purchase price paid to petitioner for...

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