United States Tax Court August 28, 1972, Docket Nos. 6725-70, 6726-70, 6727-70 (Superior Beverage Co. v. Commissioner)

lead-opinion

OPINION

Raum, Judge:

Section 1561(a), I.R.C. 1954,4 provides that if a group of corporations constitutes a “controlled group of corporations” on a December 31, the component members of such group are entitled to only one surtax exemption of $25,000 to be apportioned among them for their respective taxable years which include such December 31.