United States Board of Tax Appeals October 31, 1933, Docket Nos. 44714, 44955. (Frelmort Realty Corp. v. Commissioner)

lead-opinion

*185OPINION.

Aktjndell :

The question of affiliation during 1924 and until Roeser and DeMallie surrendered their stock in 1925 requires but little discussion. Section 240 (c) of both the Revenue Acts of 1924 and 1926 provides for affiliation “ if one corporation owns at least 95 per centum of the voting stock of the other.