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COMMISSIONER v. FIRST SECURITY BANK OF UTAH

No. 70-305.

405 U.S. 394 (1972)

92 S.Ct. 1085

31 L.Ed.2d 318

COMMISSIONER OF INTERNAL REVENUE v. FIRST SECURITY BANK OF UTAH, N. A., ET AL.

Supreme Court of United States.

Decided March 21, 1972.

Attorney(s) appearing for the Case

Ernest J. Brown argued the cause for petitioner. On the brief were Solicitor General Griswold, Acting Assistant Attorney General Ugast, Matthew J. Zinn, and Bennet N. Hollander.

Stephen H. Anderson argued the cause for respondents. With him on the brief was S. J. Quinney.

Ernest Getz filed a brief for Bud Kouts Chevrolet Co. et al. as amici curiae urging affirmance.

MR. JUSTICE POWELL delivered the opinion of the Court.

This case presents for review a determination by the Commissioner of Internal Revenue (Commissioner), pursuant to § 482 of the Internal Revenue Act,1 that the income of taxpayers within a controlled group should be reallocated to reflect the true taxable income of each. Deficiencies were assessed against respondents. The Tax Court affirmed the Commissioner's action, and respondents...

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