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Commissioner of Internal Revenue v. Western Power Corporation.

February 7, 1938

COMMISSIONER OF INTERNAL REVENUE
v.
WESTERN POWER CORPORATION.



Appeal from the Board of Tax Appeals.

Author: Hand

The North American Company, a New Jersey corporation, owned 99.8 per cent of the common stock of the taxpayer, but was not affiliated with it because of outstanding voting preferred stock of the latter. The North American Company was a large holding corporation owning stocks of public utility companies in various states of the union.

The taxpayer is a New York corporation whose business is investment in capital stock of public utility corporations. It owned 4904 12/40 shares of common stock of North American Company and also owned shares of stock in its own subsidiary corporations as hereinafter set forth. These three corporations operated in the State of California in contiguous territory. Their business was to furnish electric light and power and in some cases gas and steam. Prior to the transactions about to be described, the classes of stock, all having a par value of $100 per share, and the number of shares owned by the taxpayer were as follows:

Great Western Power Company of California

Shares

Authorized Outstanding owned by

shares shares taxpayer

Preferred stock 150,000 129,278

Preferred stock Series A 150,000 48,965

Common stock 300,000 300,000 300,000

San Joaquin Light & Power Corporation

Prior preferred stock 250,000 118,426 897

Prior preferred stock Series A 500,000 26,276 1,462

Preferred stock Series A 185,000 ...


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